NCD981475932_19940506_FCX Inc. (Washington Plant)_FRBCERCLA RA_Remedial Action Statement of Work Rev. 1 - Attachment A-OCR

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1.0 GENERAL
A'I"?ACHMHNT A
FARMERS ' COOPERATIVE EXCHANGE ( FCX) ,
STATEMENT OF WORK, REVISION 1 t
May 6, 1994 fCX 1/\./ ll---"-~ '°Vi/·
INFORMATION
1.1 DEFINITIONS
( 1) EPA -United States Environmental Protection Agency,.
Region IV.
(2) Contractor -The party with which the EPA contracts for
the services described in this solicitation.
' (3) Contract -The legally binding agreement between the EPA
and the Contractor.
(4) Site: FCX site located in Washington, North Carolina as
described in Section 3.0 of this Statement of Work (SOW).
(5) Thermal Desorption/Distillation is a treatment process
that uses thermal energy to volatilize organic contaminates
and water from soil and debris; The process must be conducteq
in an inert and/or non-oxidizing atmosphere. Heating for this
process may be directly, radiantly or indirectly supplied to
the contaminated media to be treated. However, under no
circumstances shall any fuel be combusted in the presence of
.the contaminated media. Use of either high or low temperature
systems to accomplish these objectives is acceptable. The
Thermal Desorption/Distillation system must have a recovery or
nondestructive air pollution.control system; an afterburner,
fume incinerator, or thermal oxidation system will be
unacceptable.
(6) Inert and/or non-oxidative atmosphere -For the purpose
of this contract "inert and/or non-oxidizing" atmosphere shall
mean an atmosphere inside the treatment system with an oxygen
concentration of less than 5.0% by volume.
(7) Radiantly heated shall mean the use of any non-
conductive, non-conv~ctive heating source.
( 8) Directly heated shall mean the use of hot gases to
convectively heat the contaminated media. However, this must
be distinguished . from directly fired technologies. Any
technology which allows for the presence of a flame and/or
combustion in the presence of the contaminated media shall be
considered to be directly fired. Directly fired treatment
technologies will not be considered for use for this project.
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(9) Independent Laboratory -A laboratory that is not owned, operated, organizationally or otherwise financially connected to the contractor,
' (10) A Low Gas Flow System shall mean any thennal desorption technology that uses minimal amounts of carrier gases such that the total flow of non-condensable gases exiting the desorption chamber is less than 500 DSCFM. This will be tested by a measure of the gas flow rate exiting the system condenser at 0 celsius.
1,2 INTRODUCTION
EPA Region IV is currently undertaking Removal Actions to abate an immediate threat to human health and the environment at the FCX-Washington Site, located in Washington, North Carolina. The Site is listed on the Agency's National Priorities List (NPL), and is currently undergoing a Remedial Investigation/Feasibility Study (RI/FS). As part of the on-going removal activities, EPA Region IV plans to initiate the on-site treatment of approximately 14,700 cubic yards of waste pesticides, and pesticide contaminated soil and debris.
EPA is requiring the contractor to use on-site thermal desorption or thermal distillation technology to treat the contaminated material (soil, waste pesticides) to the standards specified i~ Section 3,2, Waste Profile and Clean-up Objectives. For purposes of this statement of work, thermal desorption is not: incineration (a,k,a.-thermal oxidation), directly fired desorption, and/or technologies with direct high volume air-stack discharge, (either the system must be a low gas flow system or i,e,1 90% of all carrier gases must be recycled to the system). Alternative technologies, including but not limited to offsite Transportation and Disposal, will not be considered for award,
Site conditions are the result of an abandoned pesticide formulator. The operations covered approximately _five ( 5) acres of land located in a lightly populated residential area. Approximately 14,700 cubic yards of material have been excavated and are stockpiled on-site.
1.3 CONTRACTOR SERVICES TO BB PROVIDED
The Contractor shall proviie the following remediation services at the site:
( 1) Mobilize and operate the thermal desorption/thermal distillation unit at the site.
(2) Sample, composite, and analyze the waste to develop a treatment profile. The contractor shall be responsible for all sampling and laboratory analyses to confirm that the clean-up
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objectives have been met. All sampling and analysis shall be done in accordance with OSWER Directive 9360.4-01, Guidance for Removal Activities, Sampling QA/QC Plan and Data Validation Procedures (April 1990), EPA/540/G-90/004, and ~ Environmental Compliance Branch Standard Operating Procedures and Quality Assurance Manual, February 1, 1991, US EPA Region IV, Environmental Services Division. Both documents can be made available upon request of the Project Officer. An independent laboratory shall be used to analyze all samples.
All contractor sampling and subsequent analysis under this contract shall be subject to EPA review. EPA reserves the right, at any time, to take split samples or provide blank or spike samples for contractor analysis at no additional cost to the Government. The Contractor should be prepared to receive and analyze up to two each blank and/or spiked samples received from the Government at any time during the contract period of performance. The EPA also reserves the right, at any time, to audit the contractor's selected laboratory at no additional cost to the Government. If any of the above actions indicate that the contractor and/or its selected laboratory are not following:
a) the contractor's approved Sampling and Analysis_ Plan (reference Attachment B, Section 1.3); ·
b) EPA method 8080;
c) Sampling and Analysis protocol stated above in this section;'
the . contractor shall take immediate steps to rectify any discrepancies identified by the EPA or the contractor at no additional cost to the Government. In rectifying such discrepancies, the contractor may be required to analyze additional samples at no additional cost to the Government.
(3) Contractor shall compile and analyze all necessary data to meet Government reporting requirements. Contractor shall provide reports as described in Attachment B.
( 4) Contractor shall size the material based on their selected treatment s•ystem. Contractor shall perform all services necessary for the operation of the treatment system including, but not limited to: estimation and treatment of all contaminated materials, site preparation; identification and connection of all necessary utilities; submission of required plans and reports; mobilization and demobilization of the unit and site personnel; removal and handling of stockpiled contaminated soil; unit design; all materials handling required for the proper operation of the treatment syste~; feeding and screening of the contaminated soil; handling,
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segregating, and tracking processed soil pending analysis i and
retreating material as necessary to meet stand~rds as defined
in Section 3.2. After contractor sampling demonstrates that
soil meets the cleanup standards in Section 3.2, the
contractor shall deposit the processed soil on the site in an
area designated by EPA. The contractor shall perform site
restoration as required by 1. 3 ( 15 )'.
(5) Perform a demonstration of the actual treatment system
that will be used to process all contaminated materials at the
site, in accordance with a plan approved by the EPA. The
Contractor must start the demonstration no later than~ 45·
calendar days after EPA's approval of the demonstration plan.
The Contractor shall use the same treatment system which
successfully. completes the demonstration for the ac.tual
treatment of the remaining soil. De-mob or substitution of
the successful demonstration system is prohibited.
In the demonstration, the Contractor shall process waste that
is representative of the contaminant mass on-site, and achieve
soil clean-up . objectives as aefined in Section 3. 2. The
Contractor's selection of waste that is "representative of the
contaminant mass" shall be presented to and approved by the
Government in the demonstration plan prior to the commencement;
of the demonstration.
The demonstration should handle at least 100 cubic yards of
the waste material, but shall not exceed 1500 cubic yards. ll
shall prove the treatment system can achieve all of the
appropriate'treatment criteria andlor standaras for any by-
product streams. The demonstration shall prove tliat anyair
pollution control devices function properly, and can be
monitored appropriately. Once contaminated media has been
introduced for treatment during the demonstration, the
demonstration must be completed within 28 calendar days.
The contractor shall monitor and test for a minimum of the
following parameters during the on-site demonstration:
....,.stack Sampling-HCL; Particulates; voes; Semi-VOCs: Total r pesticides (EPA method 8080); Dioxins; Furans; Moisture;
and Gas volume.
Continuous Emisslon Monitoring-Total Hydrocarbons; GaFeeR
HeneniEle1 SarSen dienideJ and Oxygen.
Soil Sampling-Total pesticides, Dioxins; Furans; Semi-
VOCs; Total RCRA metals; TCLP metals.
The establishment of proper operating conditions ·through the
site demonstration, and the establishment of proper control
monitorir.g is essential for all aspects of the treatment unit.
For example, if a gas-phase carbon adsorption system is to be
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used in the air pollution conti::ol system, the Agency will
require the contractor to suggest proper operating parameters
and limits (such as gas temperature and moisture content in
the carbon) for the system, To allow ·the contractor
flexibility in designing and operating the treatment system
these parameters will not be dictated by the Agency in this
Statement of Work, However, the contractor must demonstrate
at all tl.J!leS that all aspects of the system can be properly·
monitored, and that proper .operating conditions can be
maintained in the treatment system. Any variation, deviation,
or excursion outside of· proper operating condi tJ_ons_(.as
I established in the demonstration) sliall result in the use of . o ---the automat-ic wastefeecisnutoff. (AWFSO). ~ I .
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After successful completion of the demonstration, the range of
operating limitations and AWFSO, operating limits for the
treatment unit and air pollution control system (i.e. oxygen
levels, minimum temperatures, residence times, mass feed
rates, gas flow rate in treatment unit, gas flow rate in air
pollution control system, etc.) will be recommended in writing
by the Contractor as described in Attachment B, Section 1.2.2.
( 6) After successful completion of the demonstration, and
after the EPA Project Officer (PO) receives and approves_
confirmatory laboratory analyses tpat show the contractor has
met the soil clean-up standards defined in Section 3.2, the PO
will issue a written Notice To Proceed. This notice will:
a. authorize the contractor to begin full-scale treatment of
the on-site waste;
b. set the operating parameters that will be used by the
contractor at all times during the full-scale treatment.
(7) During the full-scale treatment of the contaminated media
the contractor shall continuously monitor, at a minimum, the
following:
Continuous Emission Monitoring-Total Hydrocarbons;
SaJ::bea meae:Hide1 Garbea eiienidef and Oxygen.
( 8) During the full-11cale treatment of the contaminated media .
the contractor shall provide weekly summaries on the progress
of the remediation, and the previous sampling and analysis
(See Attachment B, Section 1,5),
(9) The Contractor shall minimize the discharge to the
atmosphere of any gas and/or vapor stream that has been in
contact with the contaminated media, At least 90% of all
carrier gases must be recycled to the treatment system and
collected after treatment is completed, unless a Low Gas Flow
System is used. A low gas flow system must continuously have
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a non-condensable g_as flow rate of less than...5.00-D.S.CF.H,. All
volatilized water and contaminants· shall be either: treated
further in the vapor phase and condensed; condensed and then
treatec,l; or simply condensed directly for shipment to an off-
site treatment facility. Water may be separated and
discharged from the treatment system, but only if it has been
properly treated in accordance with section 2.1.3, CWA
compliance. It is suggested by EPA, but not required, that
any collec·ted water be mixed with the treated soil so as to
provide dust suppression. If this is the route chosen by the
contractor the water must be added to the treated soil prior
to confirmational soil sampling to ensure that the addition
of the water does not re-contaminate the treated soil. If it
is necessary to bleed off gas from the carrier gas stream the
following conditions must be met: .
a. The gas must be condensed to a temperature less
than ~ 0 degrees Celsius, with any liquid
condensate being either returned to the treatment
system or collected separately.
b. The gas flow rate of the vented gas cannot
exceed 10.0% of the flow rate of the carrier gas
stream at any given time. If the carrier gas is to~
be vented at times when the treatment system is not
operating, then the mass of gas discharged shall
not exceed 10.0% of the mass of gas in the carrier
system. As an alternative to this limit for low
gas flow systems, the' total discharge of non-
condensible gases exiting the desorption chamber
must continuously be less than 500 DSCFM.
c. All carrier gas vented from the system must
meet the criteria specified in section 2.1.4, CAA
compliance. .
( 10) Using thermal desorption or thermal distillation as
defined in 1.1(5), the Contractor shall successfully remove
from the soil and debris all contaminants to meet the clean-up
objectives in section 3. 2. Once soil has been processed
through the treatment system it shall be stockpiled in an area
on site near the treatment ·unit as designated by the
Government's PO. The•contractor shall collect and segregate
the treated soil in either 500 ton or daily lots (whichever
the contractor finds more convenient) for sampling to insure
compliance with the. treatment standards found in Section 3.2.
If the soil fails to meet the required treatment standards, it
shall be processed until it meets said standards at no
additional cost to the EPA.
( 11) The Contractor shall dispose of ·all process residuals
(e.g., decontaminated water, contaminated work-clothes, the
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soil bags, etc. ) and all non-treated material in a manner
consistent with RCRA regulations (as applicable). Offsite
shipments of hazardous substances must comply'with 42 U.S.C.
Section 962l(d)(3) and the following rule: Amendment to the
National Oil and Hazardous Substances Pollution Contingency
Plan: Procedures for planning and Implementing Off-Site
Response Action: Final Rule 59 FR 49200 September 22, 1993,
codified at 40 CFR Section 300.440. If practical, various
debris, such as the soil bags or pesticide containers may be
processed through the treatment system and disposed of as non-
hazardous material. This is assuming that sampling indicates
that the material has been treated and meets the standards
specified in Section 3.2.2.
(12) The Contractor shall establish and maintain continuous
site safety and security while engaged in treatment operations
in accordance with the OSHA standards found at 29 CFR
1910.120.
(13) It is the contractor's sole and exclusive responsibility
to provide utilities to the site and to properly dispose of
all effluent streams from the site. The contractor shall
obtain approval to access power sources, bury lines, and
repair any ancillary damage to site property. These approvalli
and repairs will be the sole responsibility of the Contractor.
Contractor shall be solely responsible for securing all
requisite local construction and operating permits, if
necessary, approvals, licenses, and consents pertaining to the
movement, set-up, operation, and removal of the treatment
system and ancillary equipment.
( 14) The contractor shall comply with all applicable federal,
state; and local laws and regulations with respect to all
aspects of the treatment operations. Also, the contractor
shall meet the technical standards contained in Federal and
State Environmental and Safety regulations.·
(15) The contractor shall perform closure of the treatment
processing site (including the removal of all utility
connections, foundations, and site modifications which
are/were attributable to the contractor) in accordance with
the work plans approved by the EPA. After site work is
complete, the contr"actor shall restore the site to its
original condition prior to mobilization. All site activity
shall be completed no later than 480 days calendar after date
of contract award. Site work shall not be considered complete
until the site has been restored to its pre-mobilization
condition.
( 16) The Contractor shall prepare a final report on the
treatment of the contaminated soil.
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( 17) The contractor will be responsible for removal and
treatment of all • soiled areas affected by i;:s operations,
e.g., spills, mishandling, negligence.
( i) The contractor's verification of non-contamination in all
handling areas will be demonstrated by composite sampling (for
soil) or wipe samples (for concrete) of 300 square foot areas
or grids. Copies of sample results will be given-to the EPA
PO. The contractor will be responsible for analyzing samples
for Total Pesticides ( EPA Method 8080) in accordance with
paragraph ii below.
(ii) Handling areas will be returned to contaminate levels
less than or equal to removal action level of Total Pesticides
(EPA Method 8080) or their current condition, whichever is
greater.
(18) During start up and shutdown of the thermal treatment
unit, hazardous waste must not be fed into the unit unless the
Treatment System operating monitors are fully functional and
the unit is operating within the conditions as set forth in
Attachment A, Section 1.3(20).
( 19) Fugitive emissions from the unit must be controlled by:~
(i) keeping the operational zone(s) sealed; or
(ii) Maintaining a negative pressure lower than
atmospheric pressure. Monitoring the negative pressure
is required as part of the AWFSO.
(20) The Contractor's thermal treatment unit shall operate at
all times with a system that automatically shuts off the waste
feeder when operating conditions exceed the limits set by the
PO. The PO will derive these limits from data submitted
within the work plan. The contractor shall include
recommendations for the operating condition which will
activate the AWFSO in the work plan.
The Contractor shall be responsible for all services outlined
above. The "soil" to be treated consists of all stockpiled soil
and material contained in the one cubic yard bags in the warehouse
area.
1.4 EPA'S RESPONSIBILITIES
(1) EPA will be responsible for obtaining access to the site
within 15 calendar days after contract award.
( 2) . EPA has bagged and stockpiled the contaminated soil, but
sizing has not been conducted by EPA. As stated in paragraph
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1. 3 above, the contractor is solely responsible for estimating
and treating all contaminated soil. Additional soil size
reduction or other pre-processing shall 'be the sole
responsibility of the Contractor and shall be performed within
the scope of this contract at no additional cost to EPA.
(3) EPA will make the final determination regarding operating
conditions for the treatment system, considering
recommendations from the contractor. These conditions will be
based on the demonstration discussed in Section 1. 3, paragraph
5.
(4) EPA will be responsible for the final disposition of all
treated soil that meets the applicable treatment standards as
defined in section 3.2.
(5) EPA will respond to the contractor's proposed operating
parameters (see Section 1.3 (6) above) within seven days upon
reciept.
2.0 APPLICABLE LAWS AND REGULATIONS
2.1 FEDERAL
Although no permits are required for any on-site operations, the
Contractor shall be required to meet all of the technical
performance requirements of all applicable Federal regulations,
including, but not limited to the following regulations:
2.1.1 Resource Conservation and Recovery Act (RCRA)
Reference
40 CFR 264
A -General
Description
Standards for owners and
Operators of Hazardous
Waste Treatment, Storage, an
Disposal Facilities:
B -General Facility Standards
C -Preparedness and Prevention
Subpart
Subpart
·subpart
Subpart
Subpart
Subpart
S1:1tbpa1:t. C
.D -Contingency Plan and Emergency Procedures
E -Manifest 0 System, Record keeping, and Reporting
F -Closure aa~R~aHP¼e~s~e&-.C&±leeee~e~F;ee
Subpart H
Subpart I
SabpaF1= J
Finaeeial Re~1:1tirement.e
-Use and Management of Containers
-Tank Systems
Land '!'£eat.meat.
IaeiaeEa'£.ece
40 CFR 264.50-56
40 CFR 264.110-120
Contingency Plan
Closure Plan
, ... .,.,.,,, ..... __ _, _ __.......,..,..-.-·'I
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4Q CFll. :.lli1. 14:.l
4Q CFR :.lli4,147
40 CFR 268
40 CFR 270,16
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Cost Eetima.6e feE CleaaFe
LiaBility RequiFemeate
Land Disposal 'Restrictions
Information Requirements for
Tank Systems
2.1.2 Occupational Safety and Health Administration (OSHA)
All work conducted on site shall be in accordance with 29 CFR
section 1910, part 120. Prior to initial entry on-site, all
treatment personnel, subcontractors, and ancillary personnel shall
provide the Government project officer a certificate for a minimum
of 40 hours of Hazardous Waste Safety and Health Training, In
addition, all treatment personnel, subcontractors, and ancillary
personnel must complete at least eight hours of refresher education
each year for Hazardous Waste Safety and Health Training. The
contractor shall maintain records for the Health and Safety
training for each individual on-site. These records will show full
compliance with these training requirements and will be available
for review by the EPA ·at any time.
2.1.3 Clean Water Act (CWA)
If any process water results from the treatment of the contaminated
soil, any treatment and/or discharge of.said water shall be done in
compliance with all provisions of the CWA. Discharge limits for
the water treatment system will be consistent with the Federal
Ambient Water Quality Standards.
2.1.4 Clean Air Act (CAA)
Any carrier gas vented from the treatment system will not require
a CAA permit. However, the following standards developed with the
help of the EPA Region IV Air Compliance Section will have to be
met prior to the release of the vented gas:
Compound
Aldrin
chlordane
DDT
Dieldrin
Heptachlor •
Lindane
Methoxychlor
Maximum Concentration mg/dscm
0.25
0.5
1.0
0,25
0.5
0.5
30.0 -
In addition to the above maximum concentration limits, any air
pollution control system must meet (as defined by the CAA) _lli
Maximum Achievable Control Technology (MACT) standards. This
portion of the contractor's WorK Plan wffl be reviewed cy the EPA
Region IV Air Compliance Section. The contractor shall develop and
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implement a testing plan which will insure compliance with these standards.
2.2 STATE
The contractor shall be required to meet all of the performance requirements of all applicable State regulations that are more stringent, but consistent with the Federal Regulations referenced in Section 2.1;
2.3 Public Meetings
The contractor must attend one EPA scheduled public meeting to be held in Washington, North Carolina prior to mobilization, and be prepared to pass out literature describing the treatment technology. The contractor must also be available to aid the EPA in· answering questions about the technology. All contractor personnel shall prominently display a badge identifying themselves as contractor personnel. All literature shall be reviewed and approved by EPA prior to the meeting. This literature shall indicate input by the contractor.
3.0 SITE-SPECIFIC INFORMATION
3.1 DESCRIPTION OF THE SITE
The Site is located on Grimes Road, Washington, Beaufort County, North Carolina just immediately inside the city limits of Washington. The area is lightly populated, with roughly 600 residents living within a one-mile radius of the Site.
Washington is located on the North Carolina coastal plain and lies along side the Pamlico River. The Site is presently owned by Fred Webb Grain Company, and is operated as a trucking distribution and storage facility. The Tar River, a tributary of the Pamlico, borders one side of the Site. The wetlands of the Tar River are within the influence of the FCX site.
The FCX facility operated from 1945 until the early 1980's as a pesticide storage and blending facility for distribution to local farmers. The pesticides most prevalent at the Site consisted of the chlorinated organic p~sticides chlordane, methoxychlor, DDT, and DDE and various other chlorinated and non-chlorinated organic chemicals used-to mix and blend pesticides.
The Site was permanently closed and the buildings and warehouses were cleaned out. The majority of the property was sold to Fred Webb Grain for use as a grain storage facility. During operations as FCX, the facility routinely buried expired and waste pesticides in on-site disposal trenches. Prior to the closing of the facility, residual waste, including pesticides and
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contaminated debris were also buried in a trench on-site. The
trenches were located between the warehouse (currently leased by
Fred Webb Grain to a trucking company) and the Tar River. The Site
is generally open and readily accessible to the public.
The trenches were located approximately 100 feet east of the grain
warehouse. The trenches and storage area are bordered on the three
other sides by farmland which is not owned or controlled by Fred
Webb Grain. Immediately behind the narrow section of farmland is
a woodland swamp and the Tar River.
FCX-Washington has been ranked as an NPL Site based upon the
potential for possible groundwater and surface water migration.
The NPL score is 40.39 which resulted in the ranking of the site as
number 449 on the list. See 40 Code of Federal Regulations Part
JOO, Appendix B, Group 9. ·
3.2 Waste Profile & Clean-up Objectives
3.2.1 Waste Profile
In 1986, the North Carolina Department of Human Resources (NCDHRL
sampled the Site. The Site trip report provided with the NPL
ranking package indicated the sampling consisted of only surface
sampling, from Oto 2 inches in depth. The data provided indicated
the presence of:
Pesticide
Aldrin
Chlordane
DDT, DDE
\Me~~=X..
Range (PPM)
27.0 -1585.0
1.0 -so.a i_,__o_-__ J 1 ._1 __
.-•--· --~. ~.:_ 2 8. 0 ___,,7
Sample Type
Soil
Soil
Soil
Soil
Location
Above Trench
Above Trench
Above Trench
Above Trench
Removal data indicated that the chlorinated pesticides are the most
prevalent and widespread in the trenches, although solvents have
been detected in a few samples. Additional soil samJ?.les have not
demonstrated the presence of mercu~ whii::.h was_pr.e.s.en:t in one o!._
the Stat:e surface samples. In aadition to the above compounds
other materials detectea on-site within the trenches include:
Pesticide
Chlordane
DOD
DDT
DOE
Dieldrin
. .
Trench
Matrix
Soil/debris
Soil/debris
Soil/debris
Soil/debris
Soil/debris
Cone. Range
mg/kg
1.0 -6629.0
1.0 -500 .• 0
1.0 -19435.0
1.0 -47.0
1.0 -47.0
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Pesticide
Heptachlor
Heptachlor Epoxide
Methoxychlor
Total BBC's
Trench
Matrix
13
·soil/debris
Soil/debris
Soil/debris
Soil/debris
Cone. Range
mg/kg
1.0 -79.0
1.0 -79.0
1.0 -<130.0
1.0 -189.0
Other organic chemicals detected in the samples include; benzene,
chlorobenzene, toluene, xylene and phenol. The chemicals were
apparently used as mixing, blending or solvents in pesticide
formulations. Organic analysis indicates there are nineteen (19)
total compounds in the scan. The families of compounds consists of
chlorinated, phosphorylated, carbamated sulfur based and .various
unknown or unidentified compounds at concentrations ranging from
1. 0 ppm to 19. 0 ppm. Although the above contractions may not
appear to be extremely high, the samples were obtained from a small
specific portion of the trench. Since the trenches were not
homogeneous, the analysis should be used to indicate the types of
materials present and not necessarily the highest levels which may
be encountered. A more complete set of sampling data generated
during the soil excavation can be found in Exhibit A to this
Statement of Work.
Some of the pesticides or compounds listed above are also listed
hazardous waste under 40 CFR 261, Subpart D, and all are listed
hazardous substances under CERCLA Section 101(14).
3.2.2 Clean-up Objectives
The.contractor shall ensure that the treated soil_has a total
pesticicie concentration (P.er EPA method 8080-organo. chloride
pesticiaes and PCBs) of egual to or less tlian 170"nig7Jcg. Tlie
contractor snall conf-irm this in the fol"lowing manner: from-either
the daily or 500 ton lots (see section 1.3(10)), three independent
grab composite samples shall be taken over the entirety of the lot.
Each of these three samples must be below 1.0 mg/kg total
pesticides (see above) for the lot to be considered successfully treated. ·
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date: May 6, 1994
14
ATTACHMENT B.l
REPORTING REQUIREMENTS
1.0 Reports and Plans
The Contractor shall compile and analyze all necessary data to meet
Government reporting requirements. All reports are described in
this section, and due dates for the reports are in Attachment B.2.
1.1 SITE SPECIFIC WORK PLAN
The Contractor shall submit the site specific work plan to EPA no
later than 45 calendar days after the date of contract award. The
site specific work plan consists of the four areas outlined below,
and it shall be approved by EPA prior to the contractor's beginning
full-scale treatment operations on site. The site specific work
plan is a detailed description of the operational procedures for
the site activities. It includes, at a minimum:
l) Procedures and Plans for Mobilization and Demobilization
2) Site Operating Procedures
3) Treatment System Monitoring
4) Site Layout
':Phis uor]t plae anel its elemeate m1:1e'E hav:e eaeugJ:i ele=tail to meet the
Fe~1:1iremen'ea of 4Q GFR 264,§Q §6 CeRt.ingeaey Plaa, 4Q CFR 264,llQ
12Q Cloeere Plaa, 4Q CFR 264,143 Finaaeial ~oe1:1raaee fer Cloelire,
anEi 4Q GFR 264,147 LiaBility Re~uiremeate,
1.1.1 Procedures and plans for Mobilization and Demobilization
The contractor will
procedures and plans
plans shall include,
'1
provide a narrative description of
for mobilization and demobilization.
at a minimum, sketch(s) that show:
(1) the approximate locations of the treatment system;
the
These
(2) the fuel storage area, waste storage and stockpiling area;
(3) waste preparation area in relation to the treatment system
waste feed; •
(4) treated soil handling area(s) including stockpiles and
decontamination facilities
(5) location of office trailers, restricted areas, parking
facilities, rest rooms, water and waste water holding tanks, and
any additional equipment needed
(6) location of site utilities (telephone, water, electricity)
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15
As part of the mobilization plan, the Contractor will state its
plan for site security and access. In addition, , the Contractor
shall outline the procedures for establishing and maintaining
exclusion buffer zones, the activities conducted within each zone,
and the approximate locations at each zone.
The demobilization plan shall include procedures for:
(1) decontamination of and dismantling of equipment and any safety
concerns;
(2) site closure and site restoration in accordance with 1.3(15).
1.1,2 Site Operating Procedures
The Contractor shall describe and clearly identify the following:
(1) A flow chart identifying each step in the Site Operating
. Procedures (SOP).'
( 2) An
including
sequence.
overview of each step of the site activities,
the equipment and personnel used during each
Steps shall include but shall not be limited to:
-(a) Method of reclaiming. waste from the stockpile
prepared by others. Contractor's description shall
include but not be limited to the following:
(i) Necessity and type of protective covering for
the stockpile ( s) • Note: EPA has already covered
and/or stored the waste in existing stockpiles
and/or buildings on-site. It will be the
contractor's responsibility to maintain existing
and/or stored waste and to minimize the moisture
content of the feedstock.
(ii) Segregation procedures for incompatible
wastes.
(iii) Avoidance of fire and toxic hazards.
(iv) Avoidance and contingency for spill
possibilit!es,
(v) Dealing with heavy winds at the waste storage
area.
(b) Method of handling waste feed materials including
but not limited to:
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( i)
(if
16
Layout of the storage and/or equipment pad(s) required by contractor's treatment system). f
(ii) Size reduction and screening (if required by contractor's treatment system).
(iii) Blending or mixing procedures ( i_f required by contractor's treatment system).
(iv) Type of equipment to be used.
(v) Potential fugitive emissions and their elimination and control.
(c) Procedures used to cool the processed soil to near ambient temperatures after treatment.
·(d) Procedures·to collect a representative composite sample for analysis, and to verify that the contamination has been removed from the soil.
( e) Procedure used to suppress and control fugitive emissions from the treatment system.
-( f) Procedure used to control fugitive emissions of stockpiled processed soil.
(g) Procedures used to control, collect, and/or treat any contaminated runoff from the stockpile treatment area.
(h) Procedures for segregating and stockpiling processed soil awaiting decontamination verification and procedures for handling processed soil in cases where contamination has not been adequately removed.
(i) Procedures for closing the site after completion of cleanup. Contractor will be responsible for closure of all site areas affected by his operations.
1.1.3 Treatment System Monitoring
The contractor shall provi~e a detailed process instrumentation and control diagram (PID) of all process system monitoring sufficient to demonstrate the following: ·
(1) In the PID the contractor shall indicate the:
(a) Parameter being metered and minimum and maximum range of the parameters being metered.
( b) Range of error (+-, %, psi, gpm etc.) and signal
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17
span sent to the controller.
( 2) The
monitored
(AWFSO)·.
monitored
,
PID will clearly indicate the parameters being
as part of the automatic waste feed shutoff system
At a minimum the AWFSO operating parameters to be
are:
(a) Waste feed rate, eentiaueualy@ 1 9,§% aeeliraey,
(b) Operating temperature in all chambers.
(c) Gas flow rate in desorption chamber and air
pollution control system.
(d) Oxygen concentration.
( 3) AWFSO operating parameters shall be monitored and
recorded on a continuous basis and demonstrated to be fully
functional on a routine basis and/or upon request by EPA. The
PID will demonstrate:
(i) Monitoring shall be on line, continuous monitoring
of each operating and/or AWFSO parameter without a delay
exceeding five sec:onds. ·
(ii) The monitoring of the operating parameters shall be
continuously recorded. The records shall be placed in an
operating log which will be maintained on site by the
contractor and sha.11 be made available for EPA review at
any time.
(4) Malfunctions
(i) All malfunctions of the AWFSO shall be corrected by
the Contractor immediately upon discovery. The unit
shall not operate without any one of the AWFSO parameters
in operation.
(ii) All malfunctions of the unit shall be recorded on
the operating log,
· (iii) All corrective actions shall be fully described
within the operating log. Each log entry will include
the date, time, malfunction, person involved in the
corrective action, description of the corrective action
and retesting of cmy affected equipment or monitor.
( 5) Calibration and TE!sting
( i) The AWFSO system and associated alarms must be
tested at least we,?kly and recorded in the operating log.
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18
(ii) All tests, ,:alibration, monitoring and inspection data must be recorded in the operating l9g.
1.1.4 Site Layout
The Contractor shall provide a detailed site layout drawing showing the location of each element of the treatment system and ancillary equipment and facilities, including access roads, that clearly defines all 'exclusion zone13', buffer zones' and 'clean zones'.
1.2 Demonstration Plan and Operating Parameters
A site specific demonstration plan shall be submitted by the Contractor no later than 30 calendar days after date of contract award. This plan will be submitted in two parts, as defined below in Sections 1.2.1 and 1.2.2.
1.2.1 Demonstration Plan
Before the demonstration, th,e contractor will submit a plan showing how the contractor will fulfill the requirements of statement of work paragraph 1.3. This plan will include: the contractor's plan to select waste that is "representative of the contaminant mass"; and the contractor's recommended operating parameters. EPA will either approve or amend this plan within thirty calendar (30) days after receipt. Note: EPA' fl approval of this plan means EPA is approving how the contractor intends to conduct the demonstration. EPA' s approval of the demonstration plan does not constitute approval of the system's capability to meet treatment standards or assignment of the operating limits of the treatment unit, i.e., AWFSO, mini.mum temperatures, residence ti.mes, mass feed rates, etc. Operating_parameters will be set by the Government after successful demonstration as described below.
1.2.2 Operating Parameters
The contractor will submit its recommended operating parameters to the Government. in writing nc, later than t.lu;ee seven calendar days after the demonstration. The Government will make the final determination regarding operating parameters for full-scale treatment. The Government's operating parameters shall be used at all ti.mes during full-sca~e treatment. The contractor shall not begin full-scale treatment until the Government has provided the contractor with approved operating parameters in writing in the Notice to Proceed.
1. 3 SAMPLING AND ANALYSIS l''LAN
The sampling and analysis plan shall include a description of the specific sampling and analysis procedures to be employed during routine operations of the treatment system. This plan shall be submitted by the contractor no later than 30 calendar days aft.er
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19
contract award. This plan shall include sampling analytical methods, QA/QC samples, calibration proto,cols, conform to the requirements found in the Statement (Attachment A) paragraph 1,3(2).
methods,
and shall
of Work
(1) Sampling of the waste feed shall be in accordance with the Contractor's approved demonstration plan.
( 2) Analytical resul.ts demonstrating compliance with the treatment standards of Attachment A, Section 3. 2 are required. A copy of these results will be provided to the EPA PO.
(3) Analysis must be done by an independent laboratory.
1.4 SITE HEALTH AND SAFETY PLAN
The site health and safety plan shall include a description of the safety procedures that will be employed at the site during treatment system operations. This plan must comply with the OSHA 1910.120 standards, and be submitted by the Contractor and approved by the EPA prior to processing any contaminated soil at the site. This plan shall be submitted to EPA no later than 60 calendar days after contract award and shall include:
1) Safety administration
2) Medical surveillance
3) Personnel training
4) Hazards analy11is and designation of action levels 5) Proper safety equipment
6) Respiratory pz:otection program 7) Decontamination procedures 8) Safety zone de,lineation
9) Site access
10) Emergency response procedures and contacts
1.5 STANDARD OPERATING PROCEDURES MANUAL
The standard operating procedures manual shall include a description. of step-by-.step procedures for operation and maintenance of the treatment system and ancillary equipment. This manual shall be submitted t,::i EPA no later than 60 calendar days after date of contract award. This plan shall include a contingency plan for upset conditions, and must address emergency evacuation, emergency shut-off or bypass system( s). This plan must include notification procedures that the contractor will follow in the event any of these conditions happen. The Contractor must have procedures to notify its off··site management, the EPA PO, and EPA contracting personnel should any of the above situations occur.
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20
The standard operating procedures manual will include provisions for an operating log. In this log contractor '17ill track the performance of the unit on an hourly basis when it is in operation. This log will record amount of waste processed per day, feed rates by hour, and operating condition of the unit (temperature) by hour. The contractor shall provid1! brief, written weekly update summaries on the progress of the re1111ediation along with any sampling· and .analysis not p~eviously reported.
1.6 PROJECT SCHEDULE
The Contractor shall provid,! a site specific schedule to the PO for the items set forth below within thirty (30) calendar days after award of the contract. EPA will provide approval/disapproval of the site specific schedule within thirty calendar days after receipt.
( 1) Submission of the work plan. ( 45 calendar days after contract award.).
(2) Site preparation including but not limited to:
(a) Construction of pads for treatment system and ancillary equipment if necessary.
(b) Construction of water and waste water storage facilities (if appropriate).
(c) Implementation of security system (fences, gates, etc.)
(d) Construction or designation of parking area if necessary.
( 3) Delivery of the t1:eatment system to the site.
(4) Completion of installation and setup of the treatment system.
( 5) Completion of trea.tment system start-up and shakedown.
(6) Submission of t~e demonstration plan and the initiation of any demonstration testing.
(7) Completion of any demonstration testing.
(8) ·submission of any demonstration results.
(9) Initiation of post-test operations.
(10) Completion of treatment system operations.
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21
( 11) Dismantlement and demobilization of the treatment system,
(12) Site closure.
1,7 Final Report
.The contractor shall submit a Final Report no later than thirty (30) calendar aays after final volume of waste is treated. The final report shall summarize: the amount of the waste treated; the overall performance of the treatment unit, including, at a minimum: average feed rates per day; amount of waste processed per day; any difficulties with operation and the resolution of these difficulties; and the ope,rating log for the duration of . the project. ·
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22
ATTACHMENT B-2
SUBMISSION SCHEDULE:
Addressee A: Paul R. Peronai=d
Emergency Respc>nse and
Removal Branch (4WD~ERRB)
US EPA Region J:V
34·5 Courtland St. NE
Atlanta, Ga. 30365
Addressee B: Christina Madd~LX
Contracts, 4th Floor, Tower Bld.
US EPA Region IV
345 Courtland St. NE
Atlanta, Ga. 30365
Addressee
Demonstration Plan A
Sampling and Analysis Plan A
Project Schedule A
B
Site Specific Work Plan A
B
Recommend Operating
Parameters for Unit A
Site Health and Safety Plan A
SOP Manual A
B
Final Report • A
B
#Copies
3
3
3
1
3
1
:J.-7
1
3
1
3
1
30 days ADA*
30 days ADA*
30 days ADA*
45 days ADA*
45 days ADA*
Within :J,. 7 days of
completion of
demonstration
60 days ADA*
60 days ADA*
60 days ADA*
30 days after
completion of on-
site treatment, not
to exceed 510 days
ADA*
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*All days are calendar days.
*ADA is after date of contract award.
EPA will review all required reports and plans and provide approval, conditional approval (subject to making required revisions), or disapproval within 30 days of receipt. EPA will make the final· determinaticm regarding the acceptability of all reports and plans.
If any report or plan requires revision by the contractor, the contractor shall resubmit the report or plan to EPA within 15 calendar days after receiving EPA' s comments. EPA will review revised report/plan and provide approval/disapproval to the contractor within 15 calendar days after receipt of the revised report/plan.
In the event the Government exceeds the designated review times specified above, the period of performance will be extended by the amount of time in excess of the·required review time. The contract performance period will not be extended to allow for resubmission of any report/plan unless the Government exceeds the designated review time, or unless otherwise authorized by the Contracting Officer. -
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Page 1 of 3
AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT
2. AMENDMENT/MODIFICATION NO.
02
4. REQUISITION/PURCHASE REQ. NO.
1. CONTRACT ID CODE
3. EFFECTIVE DATE
May 6, 1994
5. PROJECT NO. (If applicable)
6. ISSUED BY (Band-Carried/
Courier Address)
US EPA, Region IV
7, ADDRESS OFFER TO (If other than Item 6)
(U.S. Mail only)
EPA Shipping/Receiving Loading Dock
345 Courtland Street
Atlanta, Georgia 30365
8. NAME AND ADDRESS OF CONTRACTOR
(No.,Street, County, State and Zip
Code: Facility:
US EPA Region IV, ATTN: C. Maddux
Contracts, 4th Floor, Tower Bldg.
345 Courtland Street
Atlanta, Georgia 30365
9A.
Code)
9B.
AMENDMENT OF SOLICITATION NO
W384010F4
DATED (See Item 11)
March 23, 1994
10A. MOD OF CONTRACT/ORDER NO.
lOB. DATED (See Item 13).
11. THIS ITEM ONLY APPLIES TO AMENDMENTS OF SOLICITATIONS
[XX] The above numbered solicita.tion is amended as set forth in Item 14.
The hour and date specified for :c·eceipt of Offers [X] IS EXTENDED. Offerers
must acknowledge receipt of this amendment prior to the hour and date
specified in the solicitation or as amended by one of the following
methods: (a) By completing Items 8 and 15, and returning one (11 copy of
the amendment; (b) By acknowledging receipt of this amendment on each copy
of the offer submitted; or (c) By separate letter or telegram which includes
a reference to the solicitation and amendment numbers. FAILURE OF YOUR
ACKNOWLEDGMENT TO BE RECEIVED AT THE PLACE·DESIGNATED FOR THE RECEIPT OF
OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY RESULT IN REJECTION OF YOUR
OFFER. If by virtue of this amendment you desire to change an offer already
submitted, such change may be made by telegram or letter, provided each
telegram or le_tter makes referenc,e to the solicitation and this amendment,
and is received prior to the opening hour and date specified.
12. ACCOUNTING .. AND APPROPRIAVON DATA ( If required)
APPROVED BY OIRM 3/84, FAR (48 CFR 53.214(c)) EXCEPTION TO STANDARD FORM 30
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~o~icitation W3H4010F4 Page 2 of 3
AMENDMENT OF SOLICITA'.rION/MODIFICATION OF CONTRACT
13. · THIS ITEM APPLIES ONLY TO MODIFICATIONS OF CONTRACTS/ORDERS. IT
MODIFIES THE CONTRACT/ORDER NO. J\S DESCRIBED IN ITEM 14.
[ ] A. THIS CHANGE ORDER IS ISSUED PURSUANT TO: (Specify authority) THE
CHANGES SET FORTH IN ITEM 14.ARE MADE IN THE CONTRACT/ORDER NO. IN ITEM
lOA.
[ ] B. THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE
ADMINISTRATIVE CHANGES (such as changes in paying office, appropriation
data, etc.) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43.103(b).
[ ] C. THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF:
[.] D. OTHER (Specify type of modification and authority) THIS UNILATERAL
. MODIFICATION IS ISSUED PURSUANT TO H.32, DELIVERY ORDERS.
E. IMPORTANT: Contractor [ ] is not, [X] is required to sign this
document and return _1_ copy to the issuing office.
14. DESCRIPTION OF AMENDMENT/MODIFICATION (Organized by UCF section
headings, including solicitation/contract subject matter where feasible).·
( SEE CONTINUATION PAGE 3, ATTACHED HERETO AND MADE A PART HEREOF. )
Except as provided herein, all terms and conditions of the document
referenced in Item 9A or lOA, as heretofore changed, remains unchanged and
in full force.and effect.
15A. NAME AND TITLE OF SIGNER
(Type or print)
15B. CONTRACTOR/OFFEROR
(Signature of person
authorized to sign.)
lSC. DATE SIGNED
16A. NAME AND TITLE OF
CONTRACTING OFFICER(Type or
Print)
Jeffrey L. Napier
Contracting Officer
16B. .UNITED STATES OF AMERICA
(Signature of Contracting
Officer)
16C. DATE SIGNED
APPROVED BY OIRM 3/84, FAR(48 CFR 53.214(c))EXCEPTION TO STANDARD FORM 30
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Solicitation WJ84010F4 Page 3 of J
1. In accordance with clause L.11, Technical Questions, technical
questions received and EPA's response are attached hereto.
2. The time and date for receipt of offers is extended,as follows:
FROM:
May 11, 1994, 3:00 pm local time
TO:
May 23, 1994, 3:00 pm local time
J. Attachments A, B-1, and B-2 are hereby deleted and superceded in their
entirety and replaced with: Attachment A, Revision l; Attachment B-1,
Revision 1; and Attachment B-2, Revision 1. For all attachments, Revision
l is dated May 6, 1994. ·
4. Offerers are reminded that this solicitation is a Request for Proposal
(RFP) and not an Invitation for Bid (IFB). Offerers are also reminded that
submission of an offer constitutes acceptance of all solicitation terms and
conditions, unless exceptions are specifically identified by offerer. Your
attention is directed to FAR 52.215-16, Contract Award, which is
incorporated by reference in Section L.l of this solicitation.
5. All other terms and conditions remain unchanged.
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TQl
ANS
TQ2
ANS
TQ3
ANS
TQ4
ANS
My question, then, is to ask whether the bidders can be told why the choice of technology required such a tight limitation?
As is the Agency prerogative in carrying outr its statutory mandates under CERCLA, the decision was made to be selective in the type of thermal treatment technology to be used on this project.
Section B.2-Under the Supplies/Services column of Schedule,-it is stated that "necessary services include, are not limited to: estimation and treatment of contaminated materials •••• ". What is meant by the estimation" in the above phrase?
the
but
all
word
The contractor is responsible for verifying to its own satisfaction the amount of material to be treated on-site, the type of soil, particle size distribution, and any other parameters about the contaminated soil which it needs to effectively design and operate its treatment system.
Section B.2., -' Under the Supplies/Services column of the Schedule, it is stated• that the scope of work includes screening of the contaminated soil. What should be done with debris and/or large rocks screened out of the soil prior to treatment?
If the debris and rocks screened from the soil can be verified free from contamination under the RCRA "contained in policy" they would not be considered hazardous waste. If this is the case they can be piled with the other debris to the south of the current stockpile. However, the contractor will be responsible for the off-site disposal of contaminated debris. The Project Officer will coordinate with the contractor to obtain an off-site land ban variance (pursuant to 40 CFR 268.44) for landfilling.
Section B.2 •• , If the actual volume of material to be processed exceeds the estimated volume (14,700 cubic yards), will Contractor receive payment for the additional material processed?
No. This is a fixed price contract. The volume estimate of 14,708 cubic yards is based on an in place survey of the stockpile done in .January 19 9 2, a tracking of the soil excavated through January 1993, and a count of the bags. This estimate also includes up to six inches of any contaminated soil lying directly below the stockpile which must be excavated and processed. Each bidder is responsible for determining their own computation for bidding purposes.
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TQS Section L.11: It appears that the technical question period
will expire before the site walks are complete. Is that
correct? · ,
ANS The deadline• for technical questions was extended to April 22,
1994 by amendment one of the solicitation.
TQ6 Section L. 16: This section specifies items to be submitted
as part of the offerer's proposal. There does not appear to
be a requirement for submittal of technical information
regarding the offerer's thermal desorption/distillation
processor or offerer's approach to the FCX Site cleanup.
Should the proposal include this information? If so, is there
a specific format for presenting the information which should
be followed? Should a complete technical proposal be prepared
detailing how the offerer will meet the process·specifications
and perform the work?.
ANS The bid submittal should be price only, the Agency will then
evaluate the low offerer for technical and contractual
responsiveness. If that offerer proves non-responsible, the
Agency will move to the next low, responsible offerer.
TQ7 Attachment A, Section 1.3(17)/i): Does the EPA have sample
results for each of the 300 square foot areas mentioned in
this section (page 7 of the Statement of Work) indicating that-
the areas are presently clean, that is, that they contain no
concentrations greater than the total pesticide removal action
level of 1.0 mg/kg? If so, will the results be provided to the
offerers prior to the submittal of the proposal? We are
concerned that Contractor may be required to remove and
process soil from these areas that were impacted by pesticides
prior to Contractor's site activities.
ANS This section refers to only the areas where the contractor
chooses to set up its equipment and operate, which within the
confines of the Site has been left to the contractor's
discretion. The Agency does not expect the contractor to
sample non-active areas of the Site, nor excavate additional
soil from these areas. The contractor may sample any area
prior to the installation of its equipment to verify pesticide
levels. The contractor is to remove all contamination
resulting from its own operation •
• TQB Attachment A, Section 2. 0: Will the Contractor be required to
file for.a State or Federal air permit?
ANS No. See 40 CFR 300.400(e).
TQ9 Attachment a, Section 2.2: What other state regulations have
been·identified as being potentially applicable or relevant
and appropriate for the FCX Site remediation? The statement
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regarding meeting State regulations is broad and could
represent a significant contingency item for the bid.
ANS The answer to this question will vary from, one treatment
system to another. Permits common to most operations, CAA,
RCRA, and CWA were identified in the SOW. In addition the
Agency requires full OSHA compliance on-site. As to other
requirements that may be applicable the Agency is relying on
contractor's knowledge of its particular treatment system. As
this is a Federal CERCLA removal action no on-site permits are
required (40 CFR 300.400(e)) and ARARs are limited to the
requirements of 40 CFR 300.415(i).
TQ10 Attachment A, Section 3.2.1: The tabulated site data indicate
that debris is present in the trench material. Is any
information available on the amount and type of debris present
in the bagged and stockpiled material? Also, is any
information available on the particle size distribution of the
soil to be treated?
ANS No information is available as to particle size distribution.
Information as to the debris is anecdotal, and should not be
taken as a guaranty of conditions in the pile. During the
last series of excavations an attempt was made to hand remove
most pieces of debris bigger than three feet long or so. Not
much· was removed, and there did not appear to be a lot of-
other debris in the soil. We estimate that less than 3% of
the material in the stockpile is larger than two inches.
TQll Attachment A, Section 3.2: No data on soil moisture content
or recoverable organic ( i-e., Oil and/or Total Petroleum
Hydrocarbon) content of the soil were found in this section or
in Exhibits A-1 and A-2. These parameters can have
significant impact on thermal treatment costs. Providing
these data to the offerers will result in a uniform basis for
the bid so that all bids may be judged on an equal basis.
ANS This information is not available.
TQ12 Attachment B, Section l.l.3{2){a): A requirement is included
that the feed rate be monitored with+-0.5% accuracy, and
that the feed rate be interlocked with the automatic waste
feed shutoff (AWFSO) system~ Unlike an incinerator, in our
thermal desorber, the•feed rate has no direct relationship to
air emissions, because the carrier gas is condensed and
recycled to the. desorber, The only potential negative
consequence of overfeeding the desorber is that the treated
soil may fail the treatment standard. This would be
identified by quality control sampling of the treated soil and
would not represent an off-site exposure risk. The
requirement to accurately monitor the feed rate and tie it to
the AWFSO system adds considerable complexity to the feed
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system and will reduce the on-line factor for the processor.
This added cost results in no benefit to the project and in no
added protection of human health and the environment. Please
delete this requirement and replace it with a requirement for
the contractor to .monitor the total mass of waste feed (or
treated soil) for billing purposes.
ANS The feed rate does not have to be wired into the AWFSO if the
contractor can provide a suitable alternative, such as chamber
temperature, pressure, and/or oxygen level. Also, the feed
rate need only be monitored to +-5.0%, not 0.5%. The SOW will
be modified to reflect these changes.
TQ13 Is pyrolysis remediation technology an acceptable
to address the Farmer's Cooperative Exchange
Washington, Beaufort County, North Carolina?
alternative
project in
ANS See paragraph 1.1 of the SOW for definitions of allowable and
unallowable technologies.
TQ14 We have some questions in regards to the Attachment "A ",
Statement of Work, Item L 1. 5. This relates to the thermal
desorption and distillation treatment of the volatile organic
contaminants and water from the soil and debris. You indicated
that.this needs to be done in a non-oxidizing atmosphere. WQ
are a manufacturer of industrial burners, fume incinerators,-
liquid waste burners, and gasifiers but we do have a concern
about how the volatile materials come off the process, there
is no indication as to how you are suggesting that to be
handled. You have indicated that it cannot be handled by an
afterburner or an incinerator system, so we are at a loss as
to what we are going to do with that material. We don't have
a problem maintaining a 5% by volume oxygen but when the
volatile materials and the exhaust come off the process, what
is to be done with that?
ANS Proposals for systems that utilize an industrial burner, a
fume incinerator, or liquid waste burner will be ·determined
non-responsive in accordance with SOW paragraph 1.1. As to
what to do with the collected contaminants please refer to
Section 1.3, paragraph 9 of the Statement of Work.
TQ15 On Item 1.2, Introduction, Second paragraph, you indicated
that 90 % of all car5ier gases must be recycled through the
system. I would think that one should be really concerned
about that because the concentration of the gases are going to
go up above the 50% of the lower explosive limits and it would
appear· that if one was to get any oxygen into the system you
might have a serious explosion. Please explain what you mean
by this.
ANS The requirement is that at least 90% of the volume of the
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carrier gas be recycled. Any volatilized contaminant phase is to be condensed and removed from the carrier gas; refer to Section 1.3, paragraph 9 of the SOW. ,
TQ16 Reference Attachment A, Statement of Work, Sections 1.3.5 and l. 3. 7: The RFP requires that carbon monoxide and carbon dioxide be monitored continuously during both the demonstration test and the full-scale treatment. These are critical control parameters for the operation of an incinerator because.there is a correlation between them and the destruction of the hazardous compounds prior to emission to the atmosphere. However, in a thermal desorber with condensation and carrier gas recycle, CO and CO2 have no significance with respect to air emissions of hazardous constituents. Rather, the condenser outlet temperature and carbon absorber outlet concentration are the critical control parameters. . Furthermore, CO · and CO2 are not hazardous air pollutants and do not need-to be monitored for any other reason but to control a combustion process. No combustion of any form occurs in our thermal desorber and we have not been required to monitor either of these parameters in previous projects. Please delete the requirement for CO and CO2 monitoring for thermal desorbers that do not perform combustion of the waste or have combustion of any type in the presence of the soil anywhere in the treatment unit.
ANS The SOW will be modified to delete·the requirement to monitor CO and CO2.
TQ17 Reference Attachment A, Statement of Work, Section 1.3.6: What period of time should be assumed by the contractor to elapse between the submission of the recommended full-scale operating parameters and the receipt of the notice to proceed? We will have a fully mobilized crew and the associated daily site expenses at this time, and need to properly budget for this scheduled delay. We would like to recommend that the conditional approval be contained in the approved demonstration test plan, provided.that certain control limits are met during the demonstration test and that the confirmatory analytical results are received and submitted to EPA. This would reduce both our and EPA's cost, and remove a significant budgetary contingency item.
ANS SOW paragraph l. 2. 2 has been changed. The Agency will respond to the recommended operating parameters within one week upon receipt •. It is the contractor's prerogative to submit any innovative suggestions in the demonstration plan. At a minimum the plan should have pre-set parameters which are met during the demonstration and ·require that verification samples of the treated soil (meeting all QA/QC requirements) be in the contractor's possession.·
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TQlB Reference Attachment B. 1, Reporting Requirements, Section
l.l.3.2(b): The operating temperature of the primary and
secondary combustion chamber in an incinerator .is a critical
performance parameter with respect to preventmg undestroyed
contaminants from being emitted to the atmosphere. For this
reason, these chambers' temperatures are automatic waste feed
shutoff (AWFSO) parameters. However, the operating
temperature of a thermal desorber has no similar requirement
for this feed permissive, since combustion does not occur in
the presence of the waste .or the soil anywhere in the
treatment system. The consequence of operation of the unit at
lower than optimal dryer temperature is that there is a
potential for soil to be discharged that does not meet the
treatment standard. This would present no emissions problem
and would be caught by the quality control sampling of the
treated soil. For a thermal desorber that condenses the
· contaminants and recycles carrier gas, the temperature that.
should be interlocked with the feed is the discharge
temperature from the condensing system. If this temperature
is exceeded, the contaminants could be emitted with reduced
control to the environment. Please delete this requirement
for thermal desorbers that do not perform combustion of the
waste or in the presence of the soil anywhere in the treatment
unit.
ANS Monitoring the temperature in the d_esorption chamber is one of-
the few ways of actively monitoring the performance of the
treatment system with minimal time lag. In addition,
monitoring the temperature and tieing it to the AWFSO provides
for the safer operation of the unit. This requirement remains unchanged.
TQ19 Please elaborate on what air pollution control system
equipment shall be required in order to meet the Maximum
Achievable Control Technology (MACT) standards (Sec. 2.1.4) ••
ANS The Agency is not specifying any particular air pollution
control technology, except to exclude afterburners, secondary
combustion units, fume incinerators, thermal oxidizers, and
other direct-fired technologies, and to require that gas
exiting the desorption chamber be condensed. The EPA Region
IV Air Compliance Branch will be evaluating the contractor's
air pollution control system using MACT criteria to determine
if the system is apprtlpriate.
TQ20 Please consider direct flame as a feasible option for thermal
desorption as temperatures can be controlled and monitored
continuously.
ANS In accordance with SOW 1.1, any direct-fired technologies will
be determined non-responsive to the solicitation.
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TQ21 Is the carrier gas considered an inert vehicle separate from
the volatile fraction of the waste?
ANS Yes.
TQ22 Can the light organics be consumed as fuel supplement after
passing through the gas treatment/recovery system?
ANS No.
TQ23 Paragraph 1.3 (4), p.3
a. Is Contractor required to provide any office, sanitary
facility and/or other support facilities for the EPA on-site
personnel? If yes, please specify exactly what will be
required.
ANS No.
b. Are there any 'restrictions that would
hour/day, 7 days/week operation? If so,
conditions and exceptions.
ANS No.
TQ24 Paragraph 1.3 (9), p. 5-6
prohibit
please
a 24
state
a. Is the -20@ Celsius condenser a requirement if the
Contractor can use other methods to meet air discharge
specifications?
ANS There is a requirement to condense the gas leaving the
desorption chamber. However, this requirement in the SOW has
been modified to condense to a temperature of 0 Celsius.
b. The specifications require that at least 90% of all
carrier gasses must be recycled to the treatment system and
the gas flow rate of vented gas cannot exceed 10% of the flow
rate of the carrier gas stream. Does this mean that 90%
recirculation of 25000 CFM system (i.e. 2500 CFM discharge) is
acceptable but a 200 CFM system cannot discharge more than 20
CFM? If so, what would be the rationale for such requirement?
Is another measure (e.g. maximum discharge gas flow rate) more
appropriate? •
ANS The Statement of Work will be modified to allow for systems
that can be operated so that less than 500 CFM will be
discharged after condensing. These "low flow" systems will
not require gas recycling. Low flow systems will be specified
as an alternative to the gas recycle · requirement. The
requirement to limit oxygen to 5.0 percent and to condense the
gas exiting the desorption chamber remains unchanged.
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TQ25 Paragraph 1.3 Cl0l, p.6
a. This paragraph refers to debris. What type (e.g. wood, brick, steel, glass, plastic, etc.), s_ize aa.d quantity of debris exists in the contaminated media to be treated by the Contractor?
ANS No information is available as to particle size distribution. Information as to the debris is anecdotal, and should not be taken as a guaranty of conditions in the pile. During the last series of excavations an attempt was made to hand remove most pieces of debris bigger than three feet long or so. Not much was removed, and there did not appear to be a lot of other debris in the soil. We estimate that less than 3% of the material in the stockpile is larger than two inches.
b. What are the specific requirements for "treated" material stockpiling? How far is the EPA designated stockpile area from the treatment unit. Will the treated material have to be trucked there? Is the treated material required to be stockpiled on liner? If so, what type of liner is acceptable? Does the run-off from the stockpile need.to be collected and treated? Does the treated material stockpile need to· be covered?
ANS It is presumed that the treated ~oil will be stockpiled as close to the contractor's treatment system as possible without interfering with the treatment operations. The treated soil stockpile area will be on-site. The method of transportation is left to the contractor. The soil does not have to be stockpiled on a liner, but the contractor is. responsible for dust suppression from a particular pile until the conformational sampling is returned and the pile verified clean. Run-off control is not required for the treated soil stockpile, as the contractor will be sampling the area after the project is completed.
TQ26 Paragraph 1. 3 Clll, p. 6
Will EPA sign all required documents, (manifests, bill of lading, etc.) for all materials shipped off-site for disposal and/or recycling? Is the debris located outside the fence and south of the contamilllilted soil stockpile to be disposed?
ANS Yes. No.
TQ27 Paragraph 1.3 (12), p.6-7
What are the specific. security requirements while the treatment operations are conducted? Examples include fencing, type . of fencing, signs, log-in/ log-out procedures, 24 hour
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security guards, etc.
ANS Specific security arrangements are left up to the contractor,
although RCRA and OSHA security requirements to restrict
access to hazardous· waste treatment facilities are applicable.
The Agency concern for security is only to the extent that the
public be protected from hazardous areas, and that reasonable
entry and exit procedures are in place. The contractor is
responsible for securing its property and equipment against
threats snch as theft and vandalism.
TQ28 Paragraph 1.3113), p. 7
What specific local and state approvals, licenses, permits
and/or consents are required to operate the thermal desorption
or thermal distillation treatment process? Please note that
paragraph 1. 3 ( 13) requires Contractor to. obtain local permits
for constructing and operating the treatment system while
Paragraph 2 .1 states that no permits are required for any
on-site operation.
ANS In reference to 40 CFR 300.400(e) no on-site permits of any
type are required. However, it is likely that the contractor
will have to perform some activities that are not "on-site".
For example, if the construction of a waterline, or power
hook-up requires a permit to have the utility brought in from
off-site then the contractor is responsible for obtaining that
permit.
TQ29 Paragraph 1.3 115), P.7
What specifications (e.g. compaction requirements), if any,
need the Contractor follow for any backfilling activity? For
seeding? For other site restoration activities? What is to be
the disposition of the fence and HOPE cover and liner from the
existing contaminated material stockpile?
ANS Reference 1.3(15): The site shall be restored to its original
condition prior to mobilization. The fence can be left in
place or will be. disposed of by EPA. The current stockpile
cover will · also be disposed of by EPA at the end of the
project. ·
TQ30 Paragraph 1.412), p.f!'
Can the EPA provide the survey data used to determine the size
of the contaminated soil stockpile? ·
ANS Yes, the survey and data on soil added after the survey are
attached to this amendment. See technical question 4.
TQ31 Paragraph 2.1.1, p.9
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The regulations referenced in this section apply to _fixed based hazardous waste treatments, storage and disposal facilities. The intention at_ FCX site is to use a mobile treatment unit. In addition, the contract d6es not include any post-closure activities. Are the remediation activities at FCX site subject to all of the referenced RCRA 40 CFR 264 regulations? If not, which specific regulations apply?
ANS The RCRA regulations referenced in this section are those that may be applicable, and will obviously vary from unit to unit. See Revision A to the Statement of Work.
TQ32 Paragraph 3.2.2. p. 13
ANS
ANS
a. Is there test data showing that 1 _ the soils is achievable? Are achieve this target?
ppm total pesticides in additives required to
_No site specific treatability
However, all offerers are required up objective.
studies were conducted.
to achieve the 1 ppm clean-
b. Have dioxin analyses been performed on the stockpiled soils? What were the results? Will they be required on the treated material to be left on-site and/or materials to be taken off-site?
Dioxin data was generated during the Agency's RI/FS conducted at the Site. All reported values were below 1,0 ppb Total Equivalents. The only dioxin sampling required for this project is during the demonstration, for purposes of showing that the treatment system in question does not generate any dioxins. No dioxin sampling is required during the full scale treatment.
TQ33 Will U.S. EPA provide us with a list of the companies who received the Solicitation?
ANS Yes. Any other vendors desiring this list should direct their requests to Christina Maddux.
TQ34 Reference Attachment A, Section 1.3(2) of the Solicitation: What are the data validation requirements? Will EPA Contract Laboratory Proceduri!s (CLP) or similar analysis and data reporting procedures be required for the soil analyses?
ANS The use of a CLP laboratory is not required. The data validation pro_cedures required for this project are outlined in the two references that were cited in this section,
TQ35 We request that EPA provide the data on which the soil treatment volume estimates are based.
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ANS See technical question 4,
TQ36 Reference Attachment B,l, Section 1,1, It appears that this
section requires the work plan to meet the requirements of 40
CFR 264 Contingency Plan, Closure Plan, Financial Assurance
for Closure, and Liability Requirements. These requirements
are typically associated with a RCRA Part B permit and may not
be applicable for the short removal action. However, the
requirements as worded would result in additional cost to EPA
for preparation of the work plan. In light of this, please
consider removing or revising these requirements.
ANS See Revision A to the Statement of Work. The contractor shall
be required to meet all applicable, appropriate and required
Federal regulations specific to the contractor's proposed
process. With respect to LOR, EPA will waive the LOR for on-. site placement.
TQ37 Reference Part I: The Schedule B.l, B.2; Attachment A, 1.3
Contractor Services To Be Provided, ( 5) -The B. 2 Schedule does
not mention the demonstration listed in Attachment A, 1. 3
Contractor Services To Be Provided, ( 5) • If this demonstration
paid for by EPA? If this demonstration is not successful
within the allotted 28 Calendar day period, what options are
available to the contractor?
ANS When the contractor submits his offer, he must submit a lump-
sum price for all of the effort called out in the SOW and
attachment B.2. If the demonstration is not completed within
28 days the contractor will be in default of the contract.
Your attention is directed to the Default clause at FAR
52.249-8.
TQ38 Reference: Attachment A, 1.3 Contractor Services To Be
Provided, (5) -During the on-site demonstration, how many
stack samples does the EPA desire to demonstrate the treatment
system can achieve all of the appropriate treatment criteria
and/or by-product streams?
ANS In order to allow the contractor flexibility in designing
their demonstration, the Agency is not mandating specific
procedures, However, the contractor will be required to fully
demonstrate the ability of the unit to remediate the soils in
accordance with all :i.1'equirements of the SOW.
TQ39 Reference: Attachment A, 1. 3 Contractor Services To Be
Provided, (9, 11) For shipments of treatment system
by-products to off-site treatment facilities, who is the
generator of these products?
ANS US EPA Region IV.
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TQ40 Reference: Attachment A, 1.3 Contractor Services To Be
Provided, (9) -What level of dust suppression is required
while full-scale treatment is under-way? ,
ANS All fugitive emissions from the contaminated soil stockpile
and the feed system to the treatment unit must be kept to an
absolute minimum. Dust suppression of the treated soil is not
required after the soil has been confirmed clean. Dust levels
must be kept low . enough to provide for safe operation of
equipment-and personnel.
TQ41 Reference: Attachment A, 1.3 Contractor Services To Be
Provided, ( 10) -For the temporary stockpiling of treated
soils on-site, it has been indicated that the City of
Washington will remove the treated soils following receipt of
analytical data ·indicating the soil meets· the treatment
standard. Given the limited available space at this facility,
where does the EPA intend to stockpile the 500 ton and/or
daily lots of soil while awaiting analytical results?
ANS Treated soils will be stockpiled on site by the contractor in
a way that will not interfere with treatment operations or the
operations of the co-occupant.
TQ42 Reference: Attachment A, 1.3 Contractor Services To Be
Provided, ( 10) In what · time frame does the City or
Washington intend to remove the treated soil from the site?
Who is responsible in the event the City of Washington fails
to remove soils in a timely manner, and due to a lack of
storage capacity for treated soils, the treatment system is
slowed and/or shut down?
ANS
TQ43
ANS
TQ44
The exact time frame for the removal of the soil has not been
worked out with the city. However, the Agency does not intend
for the accumulation of treated soil to hinder the project.
In the event that the amount of treated soil appears to be
hindering operations of the contractor or the other occupant
of the site, the Agency will have the soil removed.
Reference: Attachment A, 1.3 Contractor Services To Be
Provided, (10); 1.4 EPA's Responsibilities, (4) -Based on the
sampling and analysis of this soil in accordance with EPA
directive, who is liable for this material, if at some point
in the future soil!'s that passed testing and analysis
procedures are found to contain contaminants?
The contractor is only responsible for meeting the clean-up
objectives outlined in the sow.
Reference: Attachment
Provided, (17)(i)
non-contamination in all
A, 1.3 Contractor Services To Be
EPA requests verification of
handling areas of this operation.
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Page 45 of Attachment B. 1, with supporting figures and tables indicates that very few representative samples were actually acquired from the warehouse where the soil bags are stored. The following questions arise from this situation:
a. Is the inside of this warehouse considered a handling area?
ANS If the contractor simply removes the bags of soil from the warehouse and moves them to its treatment unit then the answer is no. The Agency only expects the contractor to remove the bags and contaminated soil in the bags from the warehouse. We do not require that the contract do any further clean-up of the warehouse, nor any sampling. However, if one of the bags is ripped or spilled in the process of moving the soil out then the contractor will need to remove the spilled material.
ANS
ANS
b. If the portion of the warehouse occupied by soil bags is considered a handling area, will the walls and ceiling require composite sampling for verification of non-contamination?
No.
c. If wooden portions of this building are found to. be contaminated, what decontamination methodology is required? And what are the required verification procedures for assessing non-contamination of po~ous media such as wood?
Not applicable.
d. Will air quality monitoring be required in the building during the removal of the soil bags? If so, how frequently does EPA desire monitoring of ambient air and at how many stations? ·
ANS The contractor is responsible for maintaining a safe work area in and around the bags for his personnel, and the need for air monitoring vs. proper respiratory protection is left up to the contractor. The Agency intends to conduct its own air monitoring on the other side of the partition from the bags to ensure the safety of the personnel working for Campbell Trucking •
..
e. If the building requires decontamination, how much of this building does the EPJI want decontaminated? In addition, how will the presence of the resident trucking firm affect the operation. Will the contractor be required_ to monitor the side of the warehouse occupied by the trucking company? Who is liable in the event of a lawsuit from this firm due to disruption of their operations?
ANS The EPA is not requiring decontamination of the building, and will.be responsible for air monitoring on the trucking company
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side of the warehouse. As long as the contractor adheres to the terms of the contract, the Agency will handle any such dealings with the trucking company or the public.
TQ50 Reference: Attachment A, 1,3 Contractor Services To Be Provided, (17)(i) -For soil areas underlying the stockpile covered with plastic, what are the responsibilities of the contractor regarding contaminants that may have migrated from the stockpile into underlying soils?
ANS The contractor shall remove and possibly remediate up to six inches of soil beneath the liner. see technical question 4.
TQ51 Reference: Attachment A, 1.4 EPA's Responsibilities, (1) -Does EPA guarantee site access to the contractor in the event of third party lawsuits and/or cease and desist orders not related to contractor negligence? If the contractor is denied access to the site for any reason beyond their control, how will compensation for this "down time•~ be handled?
ANS EPA has an access agreement in place with the property owner that provides unrestricted access to the property for purposes of this clean-up.
TQ52 Can we have a list Of site visitors and/or known bid Package-holders?
ANS The list of those who attended the Site visit is considered Source Selection Information as defined in FAR 3.104-4 and is not releasable.· If you wish to obtain a copy of the solicitation mailing list, submit a written request to the address in block 7 of this amendment, or you may fax your request to 404-347-2400.
TQ53 What are bid bonding requirement?
ANS The solicitation has no requirement for a bid bond.
TQ54 What are performance bonding requirements?
ANS The solicitation has no requirement for a performance bond.
TQ55 What are penalties foe non-completion after 480 days?
ANS If the contractor fails to perform the contractual services within the time specified in the contract, or the contractor fails to make progress, the Government may elect to terminate the contractor for default. Your attention is directed to the Default clause, FAR 52.249-8, which is incorporated by reference on page 31 of the solicitation.
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TQ56 Bid package states that off gas from the carrier gas stream
must be condensed to -20"C, however, during the site visit it
was indicated this temperature would be closer to 32 F. Please
advise what will be the true temperature requirement?
ANS The condenser requirement in the SOW has been changed to 0
Celsius.
TQ57 Can we op&rate our unit on-site prior to demo burn period? If
so, for how long?
ANS The contractor may only process clean fill during any start-up
activity in preparation for the demonstration test.
TQ58
ANS
TQ59
ANS
The solicitation indicates a start-up date of 1 August 94. Is
this award date or mobilization on-site date? How flexible is
this date? Will you negotiate a later start-up for equipment
modifications?
Section L. 9 of the solicitation states that for proposal
preparation purposes, offerers may assume a contract start
date of 1 August 1994. This date is merely provided to assist
offerers in the proposal preparation process. It is not a
contractually required delivery date.
Section F.5, page 17 of the solicitation, contains performance
milestones and contractually required delivery dates for the
solicitation. Attachment B-2 contains contractually required
delivery dates for reports. All dates in F.5 and B-2 are
expressed in calendar days after contract award.
This solicitation is a negotiated Request for Proposal (RFP),
not an Invitation for Bid (IFB). With an RFP, the Government
has the ability to negotiate aspects of an offer if the
Government wishes to do so. However, please note the
Government may award a contract .without discussions. Your
attention is directed to the FAR clause 52.215-16, Contract
Award, which is incorporated by reference into this
solicitation. (See page 71 of the solicitation.)
Will oversize debris and unprocessable.materials (i.e., bags,
liner, etc.) be allowed to be shipped to an off-site permitted
facility for disposal~
Yes.
TQ60 Does EPA want to salvage the stockpile fence?
ANS No.
TQ61 Will the contractor be responsible for any surface sampling or
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decontamination of the warehouse once the bagged soil is
removed?
ANS No. ,
TQ62 Will the contractor be allowed to operate 24 hours per day, 7
days per week?
ANS There is nothing in the SOW which would preclude a 24 hour a
day, seven days per week operation of the unit, as long as the
unit is operating within the performance parameters outlined
in the Notice to Proceed.
TQ63 Does the contractor provide EPA and its support personnel
office space at the site?
ANS No.
TQ64 How will EPA handle any contamination discovered by contractor
.during pre-project start-up sampling of_ the processing area?
ANS All pesticide levels on the site have been removed to the 1
ppm standard. The contractor shall not be responsible for any
pesticide contamination discovered at the Site above 1 ppm.
TQ65 What are the requested individual cc;mstituent detection limits"
for the Method 8080 compounds?
ANS For the soil matrix found at the FCX Site method 8080
detection limits for individual constituents are in the part
per billion range.
TQ66 Are any water supply utilities available on the site? If so,
please indicate the type of connection available, location of
service, volume or capacity, utility company or agency company
name, contact and phone number.
ANS Specific information on the type of water service available at
the site is not known. For additional information, contact
the City of Washington Utilities and Municipal Building. The
phone number is 919-975-9306.
TQ67 Are on-site sanitary connections available? If so, please
indicate type of condection, location of service, volume or
capacity, company name, contact and phone number.
ANS Specific information on the type of sanitary service available
at the site is not known. For additional information, contact
the City of Washington Utilities and Municipal Building. The
phone number is 919-975-9306.
TQ68 Please provide a company. name, contact name and/or
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number for the supplier of the existing electrical service
at the site.
ANS Specific information on the type of electrical service
available at the. site is not known. For additional
information, contact the City· of Washington Utilities and
Municipal Building. The phone number is 919-975-9306.
TQ69 Was a treatability study performed?
ANS No.
TQ70 The specifics of the demonstration are not provided.
ANS
ANS
a. Will the demonstration consist of three separate runs? Will
the usual 720-hour shakedown period be allowed? Please provide
more details and clarify the difference between the required
demonstration and a RCRA trial burn.
In the demonstration plan, the contractor is allowed to
propose a demonstration structure that it feels can
sufficiently demonstrate the technology in the given 28 day
time frame. This plan is subject to EPA approval before the
Contractor may proceed with the demonstration. The contractor
can use the time available prior to the demonstration for
equipment shakedown, as long as. no contaminated soil is-
processed. Since no on-site inci'neration is to be allowed
nder this contract the RCRA trial burn requirements do not
apply. The Contractor may model his demonstration after a
RCRA trial burn.
b. The demonstration requires soil testing. Is this influent
soil (feed) or effluent soil (treated) or both?
Both.
TQ71 Will the BIF regulations apply? If so, please explain how.
ANS No. Since no contaminants will be burned on-site the BIF
regulations will not apply.
TQ72 How will interim operation be handled? Will the contractor be
allowed to proceed at 75% of demonstration burn throughput?
Further, submittal of "final operating parameters in three days
does not allow sufficient time for receipt of final analytical
reports •. How will this be handled?
ANS If the contractor would like to propose a conditional approval
for interim operations it should be included in the
demonstration plan ( see answer t6 TQl 7) • To allow the
contractor more time, the SOW requirement for the submittal of
operating parameters (Attachment B-1 paragraph 1.2.2) has been
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changed to 7 days.
TQ73 Textual accounts and reports of early investigatory work note
the presence of Mercury (Hg) and Copper (Cu). ,In the absence
of data to the contrary, it is logical to assume that metals
will be present in the soils. Further, Arsenic, Lead, and a
large number of other metals typical of pesticide formulations
could be present. With this in mind, the following questions
are relevant:
ANS
a. Is data available showing concentration levels of metals in
the soils?
Yes. Metals data is available in the Agency's
completed at the Site in the Spring of 1993.
in the public record for the Site.
RI/FS which was
It is available
b. Have any studies been performed to demonstrate or predict
the metal concentrations in the treated soil following thermal
desorption?
ANS No.
c. Will the treated soils be tested for metals dur·ing
operation ( see question b)? If so, what contingencies are.
planned, if the treated soils show unacceptable metal levels~
Will alterative or additional treatment of treated soils with
high metals be the responsibility of the contractor, the EPA,
or will this be handled on an as needed basis under change
order circumstances?
. ANS Yes, metals testing is required during the demonstration phase
only. Metals testing is for informational purposes only. The
contractor is only responsible for the removal of pesticides
in accordance with the Statement of Work. If unacceptable
levels of metals are detected in the treated soil, the Agency
will arrange for proper disposal of the treated soils.
d. If treated soils require further treatment for .metals
prior to disposal, what basis should be used to determine
fixed cost?
ANS Not applicable.
• TQ74 Treated soil is to be sampled "three grab composites." Later,
it states that all three must pass. Please clarify "three
grab composites." ·
ANS Please refer to the two guidance documents for sampling and
analysis referenced in paragraph 1.3(2) of the SOW.
TQ75 The treated soil is to be analyzed by EPA method 8080 with
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a cleanup criteria of total pesticides of
Specifically what are the compounds of interest
detection limit(s) apply?
f
1 mg/kg.
and what
ANS All compounds identified by EPA method 8080 are of interest
and the detection limits for these individual constituents for
this soil matrix is in the part per billion range.
TQ76 Will air monitoring of the site, work area, or site perimeter
be required? If so, please give further information.
ANS The contractor is responsible for any and all air monitoring
that may be required under OSHA or NESHAPS for its operations.
The development of such an air monitoring program is the
responsibility of the contractor. ·
TQ77 Were the air samples (reported page 45-49 of Exhibit A)
collected during or after bagging operations? Specifically,
what materials handling activities were occurring during
sampling? What time period do sampies represent?
ANS The air monitoring was conducted as soil was being bagged
the bags were being transported into the warehouse.
samples were eight hour time weighted averages.
and
The
TQ78 What parameters, frequency of sampling, etc. will be imposed
on the waste water?
ANS The waste water streams may vary from treatment system to
treatment system in both quantity and quality. The
contractor's demonstration and work plans should include
·parameters to demonstrate that any waste water stream produced
by the unit is free of pesticides.
TQ79 Does the site contain a productive aquifer? If so, please
provide further information.
ANS All available Hydrogeologic information is provid~d on page 7
of Exhibit A.
TQ80 Is there a limit on the size or number of sample(s) that may
be collected during the site visit? ·Will the contractor be
allowed to sample the bagged soils? How will the contractor
obtaina representat.itve sample?
ANS During the site sampling visit, the Project Officer cut holes
in the stockpile's protective cover to allow potential
offerers to sample. Pote.ntial offerers were also provided the
opportunity to sample the bags.
TQ81 Is bonding required for this project? If so, please describe
the type and appropriate amounts.
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ANS The solicitation has no bonding requirements.
TQ82 Do liquidated damages or penalties apply to this contract? If
so, please describe the applicable conditions'and amounts.
ANS The solicitation has no liquidated damage provisions.
TQ83 Are there any MBE/WBE requirements for this project? If so,
please describe the categories and percentages.
ANS Large businesses are.required to submit a small business and
small disadvantaged business subcontracting plan as part of
their offer. See the FAR clause at 52. 219-9 for specific
details on plan requirements.
TQ84 Once an Offerer's bid is determined
what criteria· will be used to
contractor's technology with regard
process.
to be low and responsive,
judge adequacy of· the
to its thermal desorption
ANS See FAR 9 .104-1 for the ge.neral standards to determine
responsibility. During the Pre-Award Survey the low offerer
must prove he is capable of meeting the technical requirements
of the SOW. ·
TQBS Upon confirmation sampling of treated soil, how is clean soir
disposed? If picked up by others; who performs the loading?
ANS The SOW requires the contractor to deposit the treated soil
on-site in an area designated by the EPA PO. (SOW section
1.3(10)). EPA is responsible for the disposition of all soil
that has met the clean-up standards.
TQB6 Is it. necessary that the proposed technology use a carrier
gas, or can an anaerobic environment be maintained through other means?
ANS If an appropriate technology can be sited that does not use a
carrier gas so that less than 500 DSCFM are discharged, then
there would be no recycle requirement. However, the exit gas
will still have to be condensed and a 5~ limit of oxygen in
.the desorption chamber must be met. See SOW paragraph 1.1(8)
for excluded technologies.
• TQ87 Must the contractor operate the condensing system to a
temperature of minus 20 degrees Celsius or can the vendor
simply operate the system such that the gas meets the
appropriate discharge criteria at the point it is discharged
to atmosphere? ·
ANS The condenser criteria has been changed to 0 degrees celsius,
but the criteria to condense the exit gas remains unchanged.
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TQ88 Reference Attachment A, Section 2, 1 -1, Several of the
regulations specified are not appropriate for this project and
should be removed from the specification, These include:
40 CFR 264 Subpart F -Closure and Post-Closure,
This is not typically an ARAR under CERCLA and
contains numerous administrative. requirements that
are not relevant to this project.
40 CFR 264 Subpart· G -Financial Requirements.
These requirements are written for a TSD facility
and are not appropriate for an on-site removal
action.
40 CFR 264 Subpart J
appropriate, since
treatment.
-Land Treatment.
we will not be
This is not
doing land
40 CFR 264 Subpart K -This is not appropriate
since we will not be using an incinerator.
40 CFR 264.142 -Cost Estimate for Closure. This
is not appropriate for an on-site removal action.
40 CFR 264,147 -Liability Requirements. This is
not appropriate for an on-site removal action-
40 CFR 268 -Land disposal Requirements. These
requirements mandate testing treated material by
TCLP. They also require treated listed material
like the site soil to be sent to a Subtitle C
landfill for disposal. Neither of these activities
are in the Scope of work for the project. Will EPA
issue a waiver of this LDRs for on-site placement?
Not all of the requirements of this regulation are
appropriate for this project. Will EPA remove some
of these requirements from the bid package?
ANS See Revision A to the Statement of Work. The contractor shall
be required to meet all applicable, appropriate and required
. Federal regulations specific to the contractor's proposed
process. With respect to LDR, EPA will waive the LDR for on-
site placement. •
TQS-9 Reference Attachment A, Section 3. 2. 2-Please clarify whether
the soil treatment criterion is 1 ppm for each pesticide or 1
ppm for the sum of the concentrations detected for all of the
pest'icides. If it is the sum, clarify that concentrations
reported as ND may be treated as zero in the calculation.
ANS Sum total of all pesticides detected, with ND counted as zero.
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TQ90 Reference Attachment A, Section 1.3 (9)a:
The temperature at which the carrier gas is condensed (less
than -20 degrees Celsius) appears to be 1 excessive. A
temperature of 0 degrees celsius would seem to be adequate in
this situation. Please comment.
ANS The condensing requirement has been changed to 0 degrees
celsius.
TQ91 Reference Attachment A, Section 1.3 (4)
The contractor is responsible for sizing the material based'on
its treatment system. It is anticipated that material
unsuitable for thermal desorption such as rubbish, cobbles,
and other construction debris will be segregated during
sizing operations. Can this material remain on-site? If not,
who is responsible for off-site disposal?
ANS Non-contaminated debris which cannot be processed can be left
on-site with the debris EPA has already screened. The
contractor is responsible. for disposition of any_ contaminated
debris, but EPA will sign as waste generator and obtain an
off-site LOR disposal variance per 40 CFR. 268.44.
TQ92 Reference Attachment A, Section 1.1 (5)
Please define "in the presence of the contaminated media."
Does this mean a direct contact of the contaminated material
with the fuel source (flame)?
ANS Yes. No contact of flame, burning fuel, or any direct fired
technology will be acceptable.
TQ93 Reference Attachment A, Section 1.3 (5)
ANS
What is the length of time in which the EPA will respond to
the contractor's submitted demonstration plan?
Your attention is directed to Attachment B-2 of
solicitation. This attachment outlines the EPA's and
contractor's responsibilities with respect to due dates
all reports.
•
the
the
for
TQ94 Can the thermal desorption unit operate on a batching type
basis rather than on a continuous feed basis? If so, does the
thermal ·desorption system need to be equipped with an
automatic waste feed shutoff?
ANS Yes. If the batches are truly singly charged to the chamber,
as opposed to being batched into a hopper and. then
continuously fed to the chamber until the hopper is empty,
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then no AWFSO would be required.
TQ95 Reference Attachment A, Section 1.3 (7)
Why is the contractor required to perform continuous emission monitoring for carbon monoxide, carbon dioxide, and oxygen if the thermal desorption system is not equipped with a thermal oxidizer and ninety percent of all the carrier gases are to be reused.
ANS The requirement to monitor for CO and CO2 has been deleted. Oxygen is required to be monitored to ensure that levels remain below 5.0% as specified in the SOW.
TQ96 Reference Attachment A, Section 1.3 (13)
What is the process and time frame necessary to access the site power? What type of power is available?
ANS Specific information on the type of electrical service available at the site is not known. For additional information, contact the City of Washington Utilities and Municipal Building. The phone number is 919-975-9306.
TQ97 Reference Attachment A, Section 1.3 (19)
Please define sealed ( operational zone) as it pertains to. controlling fugitive emissions from the unit.
ANS If negative pressure is not used then mechanical means (such as flap valves or air locks) must be used to prevent contaminated soil being blown back. out or otherwise released from the treatment unit.
TQ98 Reference Attachment A, Section 2.1
Will the contractor be required to obtain any state and/or local air quality permits?
ANS No.
TQ99 Reference Attachment A, Section 1.3 (4)
ANS
TQlllll
If size reduction of. the waste stream is required, what operational constraints will be required of the contractor to control fugitive emissions?
Contractor will define how any potential fugitive
will be eliminated or controlled in the Site Procedures. (See Attachm_ent B.l, paragraph 1.1.2.)
emissions
Operating
What is EPA's anticipation or time allowance from the
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Receipt of analysis after Demonstration to issuance of
Notice to Proceed?
ANS EPA will respond to the submittal of confirmauional sampling
and operating parameters within seven days. See Attachment B-
l, paragraph 1.2.2.
TQ101 Please identify the location of the Borrow Pit referred
to and the approximate quantity of material used to cover
the tarp? Is that quantity included in, or in addition
to the .stated estimate . of .13, 700 cubic yards of
contaminated material stored under tarp?
ANS The borrow pit was local in Beaufort County, with the Agency
using the same pit as source of backfill for the excavated
areas as well as to anchor the tarp. The Agency sampled the
soil from the pit on several occasions to confirm it had less
than l ppm total pesticides. Approximately 10 to 20 cubic
yards of this material was used to anchor the tarp, and within
the accuracy of the survey of the pile it is included in the
estimate.
TQ102
ANS No.
Is there a requirement to use an US EPA Contract (CLP)
Lab on this project, or on any parts of this project?
TQ103 Please clarify the statement that the Contractor will be
required to dispose of only the soil containing bags but
not any of the debris generated from treatment activities
or the soil separation process on site.
ANS The contractor is responsible for the disposal of t~e bags
that are in the warehouse. Once emptied of soil the bags will
be considered RCRA empty containers, and not hazardous waste.
As for the remainder of the debris in the pile please refer to
the answer to TQ91.
TQ104 Please clarify the reference ( Specification 2. 1.1 -
RCRA) to the requirements of 40 CFR 264, et seq. It
appears that this requirement would require a Part B
Filing, financial responsibility and funds the contractor
to treat this material on-site. As we are not receiving
Hazardous Waste• but merely treating on site under an
existing Emergency/Remedial Response Action, we cannot
see how this applies. Please advise if this is being
referenced as a technical guidance document only, and if
so, please the extent and scope and limitation.
ANS Please refer to the answer to TQ88.
TQ105 Please address the question concerning any specific
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limitations on the use of the site and buildings thereon,
specifically work hours, adjoining tenant access, access
and use of soil bag storage area and additional fencing.
f
ANS The current building tenant will be using his half of the
building during this project. During performance, the
contractor shall not restrict the entry or exit of vehicles
from Campbell trucking. Entry to the work area should be
accomplished by driving around the rear of the building (EPA
side) so · as not to pass the front entrance of Campbell
Trucking. Exit should be accomplished in the same manner.
The area on the south side of the property in the vicinity of
the current stockpile is all available for use (power easement
excepted), as well as the western portion of the property and
warehouse. There are no restrictions on work hours. No
additional fencing is required by the SOW.
TQ106 Are there any additional limitations on the generation or
source of the heat used by the system to volatilize and
destruct · the contaminants, if the requirements of no
polluting off-gases and no direct firing contact,
utilizing radiantly• supplied heating, but without an
afterburner, fume incinerator or other thermal
incineration system are otherwise met?
ANS No. Restrictions on acceptable. process technologies are
identified in the SOW.
TQ107 Can treatment continue while the sampling of the 500 ton
or yard batches are undergoing analysis if the piles are
segregated?
ANS Yes.
TQ108 Request for Documentation
ANS
a. Please provide, copies of. the site topographical ( and
boundary, if available) survey which were performed at
the FCX Site to assist us in confirming quantities of
material;
See the answer to technical question 4. A survey was
conducted of the pile, not the Site, but it is attached.
Site diagrams in th! Attachment tc:i the SOW are the
"boundary diagrams" readily available.
only
The
only
b Please provide a copy of OSWER Directive 9360.4-01,
Guidance for Removal Activities, Sampling QA/QC Plan and
Data Validation Procedures (April 90) EPA/540/G-90/004;
ANS If you would like a copy of this document, please send a
separate, written request to the address in block 7 of the
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solicitation, or you may fax your request to 404-347-2400.
c. Please provide a copy of The Environmental Compliance
Branch Standard Procedures and Quality Assurance Manual,
1 Feb 91 ( US EPA Region IV, Environmental Services
Division);
ANS If you .would like a copy of this document, please send a
separate, written request to the address in block 7 of the
solicitation, or you may fax your request to 404-347-2400.
d. Please provide a copy of the Record of Decision (ROD)
for this Site.
ANS No ROD concerning the final disposition of the soil has been
issued by the Agency.
TQ109 Please provide a list of plan holders and a list of site
walk attendees.
ANS See answer to technical question 52.
TQ110 Is the HDPE pile liner considered hazardous material?
What about the bulk lift bags and the visqueen material
in the warehouse?
ANS Once free of contaminated soil the•pile liner, bulk lift bags,
and other containment materials will be considered RCRA empty
containers, and not hazardous material.
TQlll Will the EPA sign all permit documentation, as required
for local permits (eg. Erosion Control, Water Discharge,
etc.)?
ANS EPA will sign any local permits required.
TQ112 How often will carrier gas vented to atmosphere be
required for analysis to meet the CAA standard cited on
page 10. Section 2.0 -Applicable Laws and Regulations?
ANS Sampling a·nd analysis of gas discharges from the treatment
system will be addressed in the contractor's sampling and
analysis plan. The sampling and analysis plan requires the
contractor to describe sampling and analysis procedures to be
used during "full scale operation."
TQ113 If a thermal desorber has the temperature capabilities to
drive off all hydrocarbons and has a thermal oxidizer
unit that can reach temperatures up to 1900 F with a six
second retention time, can this unit be equipped either
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ANS No.
with carbon canisters or a wet scrubber and meet the
criteria set forth not as a closed system but as a viable
alternative.
TQ114 Please define carrier gas requiring 90% recycle (note
Attachment A, Section 1.3 (9) and Section 1.3 (9)b) if a
5 to 10 cfm nitrogen purge is used to sweep the vapors
and steam.
ANS The steam will not be required to be recycled, especially
since it will be condensed to 0 celsius and likely discharged
as water. It is assumed here that the "vapors" referred to
here are the materials volatilized from the soil itself, which
would not be considered part of the carrier gas stream. If
the resulting gas flow rate exiting the condenser is less than
500 DSCFM then no carrier gas recycle would be required (see
answer to TQ24b). However, if the low flow conditions could
not be met then the nitrogen sweep proposed in this scenario
would require recycle, and 90% of the 5 to 10 cfm would have
to be returned to the desorption chamber. Please note that
the air discharge rate would be limited to 10% of the nitrogen
and steam gas flow rate.
TQ115 How will non-detect values be weighted in calculating the-
"total pesticide concentration" of equal to or less than
1.0 mg/kg as identified in Attachment A, Section 3.2.2,
and is this is on a dry or wet weight basis?
ANS Non-detects are counted as zero. The calculations should be
on a dry weight basis.
TQ116 Will it be possible to obtain some relief from the
schedule? This fast-track schedule will limit
competition because it is not realistic to assume that
contractors have the specific type of equipment required
for this project ready and waiting· in the yard.
Therefore, a more realistic time frame . for Start of
Demonstration would be 60 days from the approval of the
Demonstration Plan as shown in the proposed schedule.
Secondly, submission of recommended operating parameters
within 3 days would not give adequate time for analysis
of·stack samplin~ data if sampling was delayed until the
end of the demonstration period. We suggest that EPA
consider increasing this time period from 3 days to 14
days. In terms of the overall impact of these time
changes on the schedule, we have included a proposed
project schedule for your review. We suggest that you
consider increasing the total project from 510 to 600_
days. This 17. 6% increase in the project duration should
not adversely affect EPA since the increase in time is
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prior to thermal treatment where EPA has oversight coats.
ANS The Agency will reschedule the start of the demonstration to
45 days after the approval of the Demonstration Plan. The
period to submit recommended operating parameters will be
extended to seven days. The overall time for the completion
of the project remains unchanged. These changes have been
made to the appropriate parts of the SOW.
TQ117 If the vent gas meets the CAA standards listed in
Attachment A, Section 2 .1. 4., can it be recycled back to
the firing chamber of the indirectly heated thermal
desorber?
ANS No,
TQllB If steam is used as the carrier gas, and therefore fully
condensed in the cooling/chiller system, can we discharge
all of the remaining air resulting from air entrained in
the waste and minor system leaks?
ANS Air discharge rates would be limited to 10% of the steam flow
rate plus any other sweep gas used, unless the total discharge
of non-condensables is less than 500 DSCFM ( see answer· to
TQ24b) •
TQ119 Is there any treatability data available to indicate
treatment parameters necessary to meet the 1. 0 mg/kg
total pesticide clean-up requirement?
ANS No site specific treatability work was done, however there was
ample evidence in current literature to indicate that the 1.0
mg/kg treatment standard could be met.
•
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MEMORANDUM
Subject: FCX Excavation, Bagging
and Backfill Summary
Excavation Summary
Stockpile Volume (Thru Jan. 92)*
Excavation Volume (9/12/92-9/16/92)
Excavation Volume (11/17/.92-11/23/92)
Excavation Volume (ll/30/92-12/9/92**)
TOTAL
. Bagging Summary
Bagging Volume (1,744 each@ 1.75 yd3/bag)
Estimated Volume
* Barrow Survey
** Completed Excavation
Backfill Summary
Backfill Volume (12/9/92-12/10/92) •
Estimated Volume
,
1,350 yd'
3,075 yd'
4,570 yd'
5,700 yd'
14,700 yd'
(3,110 yd')
11,600 yd'
3,250 yd'
3,250 yd'
-·~t ..
a ' ; .
© .. .. ,.
0 . .., .. . .. N
. --r® ------
l " '!/-. ' f J I) ~
~ $ ., t J. t ® -Jo
~
--
• --:1"
"' \{l
_I
, .
I
I ,
I A = 51.3417
I B = 12.7673
C = 28.6258
I D = 37.5839
E = 17.8357
I F = 27.2204
G = 32.8780 I H = 18.8184
I I = 10.6860
J = 14.7513
I K = 73.4907
L = 60.1397
I M = 7.3627
I N = 13.9268
0 = 14.8231
I p = 13.4252
Q = 89.4784
I R = 190.6303
I s = 610.9052
T = 12.0793
I TOTAL YARDS
1346.7699 36,400 FTl
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