12639525Q0087 Amd 1.pdf
PDF 162 KB Posted
- Attached to
- Air Quality Permit Support - Mobile Incinerators Federal contract opportunity
- Solicitation number
- 12639525Q0087
About this file
This document is an Amendment (Amendment 0001) to Solicitation 12639525Q0087 for Air Quality Permit Support services for mobile incinerators, issued by USDA-APHIS-ASD-SCB. The amendment includes questions and answers from potential contractors regarding the solicitation, highlighting significant challenges in estimating costs and permitting requirements for air quality permits across multiple states. Key challenges include the mobile nature of the incinerator units, variability in state permitting processes, and difficulty predicting specific location and permit needs, which will only be known during an actual disease outbreak.
The document reveals that contractors are seeking clarification on how to estimate costs for tasks involving researching permit requirements, reviewing exemptions, and completing air quality permit applications for mobile incinerators. The solicitation requires fixed-price submissions, but contractors argue it is impossible to accurately quote costs due to numerous unknowns. The amendment suggests the contract will function through task orders, with permits being sought as specific disease outbreak locations are identified. The potential contractor demonstrates extensive experience in pathological waste incineration, having worked on over 100 projects at facilities like the USDA National Animal Disease Center and CDC, and recommends revising the solicitation to focus first on qualifications rather than predetermined cost estimates.
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Offers 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 or (c) By separate letter or electronic communication 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 letter or electronic communication, provided each letter or electronic communication makes reference to the solicitation and this amendment, and is received prior to the opening hour and date specified.
E. IMPORTANT: Contractor is not is required to sign this document and return copies to the issuing office.
AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT 1. CONTRACT ID CODE
2. AMENDMENT/MODIFICATION NUMBER 3. EFFECTIVE DATE 4. REQUISITION/PURCHASE REQUISITION NUMBER 5. PROJECT NUMBER (If applicable)
7. ADMINISTERED BY (If other than Item 6) CODE
STANDARD FORM 30 (REV. 11/2016)
Prescribed by GSA FAR (48 CFR) 53.243
FACILITY CODE
9A. AMENDMENT OF SOLICITATION NUMBER
9B. DATED (SEE ITEM 11)
10A. MODIFICATION OF CONTRACT/ORDER NUMBER
10B. DATED (SEE ITEM 13)
11. THIS ITEM ONLY APPLIES TO AMENDMENTS OF SOLICITATIONS
The above numbered solicitation is amended as set forth in Item 14. The hour and date specified for receipt of Offers is extended. is not extended.
12. ACCOUNTING AND APPROPRIATION DATA (If required) copies of the amendment; (b) By acknowledging receipt of this amendment on each copy of the offer submitted;
13. THIS ITEM APPLIES ONLY TO MODIFICATIONS OF CONTRACTS/ORDERS.
IT MODIFIES THE CONTRACT/ORDER NUMBER AS DESCRIBED IN ITEM 14.
CHECK ONE A. THIS CHANGE ORDER IS ISSUED PURSUANT TO: (Specify authority) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT ORDER
NUMBER IN ITEM 10A.
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)
Except as provided herein, all terms and conditions of the document referenced in Item 9A or 10A, as heretofore changed, remains unchanged and in full force and effect.
15C. DATE SIGNED
15A. NAME AND TITLE OF SIGNER (Type or print)
16C. DATE SIGNED
16A. NAME AND TITLE OF CONTRACTING OFFICER (Type or print)
14. DESCRIPTION OF AMENDMENT/MODIFICATION (Organized by UCF section headings, including solicitation/contract subject matter where feasible.)
PAGE OF PAGES
6. ISSUED BY CODE
8. NAME AND ADDRESS OF CONTRACTOR (Number, street, county, State and ZIP Code) (X)
CODE
15B. CONTRACTOR/OFFEROR
(Signature of person authorized to sign)
16B. UNITED STATES OF AMERICA
(Signature of Contracting Officer)
Previous edition unusable
APHIS-ASD-SCB
N/A
FAR 52.243-5 Changes
Linda W. Washington
Response to questions.
USDA-APHIS-ASD-SCB
4700 RIVER ROAD, Unit 45
RIVERDALE, MD 20737
USDA-APHIS-ASD-SCB
4700 RIVER ROAD Unit 45
RIVERDALE MD 20737
1147052
12639525Q0087
1 5
04/15/2025
Please specify mobilization, operation and/or maintenance tasks for the awarded contractor, if any, relative to the operation of the incinerators. Contractors will not be operating units only providing permit acquisition support as described in the statement of work. Note that operating manuals included in the request for quote are for potential bidders’ information only and will be the units to be permitted.
Will the USDA consider Past Performance examples for this project? Yes.
Is this a new or a follow-contract number? This is a new requirement there is not an encumbent.
Question Regarding the Solicitation - How is it Possible to Estimate Workhours & Costs for all Listed Work Items? Please provide your cost estimate addressing tasks. If there are assumptions, please recommendations.
The Solicitation requires the submission of cost tabulations for the Schedule of Items listed on pages 4 - -price amounts for providing all of the work and services as shown on pages 2 – 5 of the Solicitation and the 3 Tasks shown on page 3 of the Statement of Work. The scope of work for these 3 Tasks is clear and we have provided the work of these Tasks on many projects; however, there are too many unknown and variables to be able to estimate le requirements to be able to derive meaningful unit and total prices for the listed Schedule of Items. In other words it’s not possible to derive meaningful NTE cost estimates for most of the listed Schedule of Items. To explain and elaborate:
Task 2 - Research and provide review of permitting requirements (by State/Territory)… of this Task because state/territory permitting requirements have been established and ulatory agency, reviewing current applicable air permitting regulations and requirements, and
Task 1 - Research and provide review of Research and provide review of general exemptions/exceptions under CAA (or other pertinent federal, state, or local law/statute or regulations…
The intentions of this Task are well understood, but it’s essentially not possible to complete applications to each state and territory. To explain, the CAA and air permitting requirements included in state and local regulations specify permitting requirements and procedures…but they do NOT list or specify “permitting exemptions/exceptions” - meaning there are no “general exemptions/exceptions” in the regulations that can be “researched and reviewed.” Accordingly, they only way to determine if it will be necessary to address or
; await agency review comments; and then to make appeals for exemptions or exceptions as necessary in response to agency objections or disapprovals.
Request is to pursue and submit air permit applications that can be used in the event of an emergency. Some States may have exceptions and/or expedited permit processing in the event of an emergency and have been used.
laws, statutes and regulations” but it’s virtually impossible to check and research if there are any applicable air permitting regulations or requirements for each and every local, regional, or municipal jurisdiction areas throughout the country and in each state --- there are far too many making it virtually impossible to do so. Understood each will be unique.
Consider startintg at the highest level and work towards local air authorities and permit applications/processes. If at the State level a permit can’t be obtained or put in place in the event of an emergency, then identify and purse State regional permits under the local air authorities, etc.
Task 3 - Complete air quality permit applications and assist USDA APHIS to successfully obtain the required permits…
As discussed above, we’ve successfully completed air permit applications and obtained approvals for many pathological incinerator systems in many states, and, accordingly, we’re very familiar with requisite air permitting requirements as well as in the seeking of permitting requirements for each state vary widely; likewise, it’s impossible to estimate the
Solicitation. Air permitting in several states is a relatively simple, straightforward process basically involving the submission of a permit screen modeling to evaluate potential impacts on nearby communities; some require the preparation and submission of facility drawings and equipment layouts; some require the preparation and submission heat, combustion and mass balance number of states because of the mobility if the incinerator unit to be approved. Units are Complete air emissions testing was conducted and can be provided upon award. Units are not expected to operate more than 3 weeks at a time. The units will be operated periodically as part of a maintenance program per the manufacturer’s recommended maintenance schedule.
Question Summary:
In light of the above, it doesn’t appear possible to develop and propose a Unit and Total
Estimate Cost for the site-please explain. Units are mobile and will only be operated for recommended maintenance not approached, and applications and permits can be submitted and/or developed to submit under emergency conditions. Pre-negotiates with regulators from regional, state and counties can be approached so that applications/authorization can be obtained. Request is to have those discussions, identify what can be done and then executed. If there is no solution, please identify, document
Solicitation Comments - Suggestions
• Recommended Solicitation Evaluation Criteria
The Solicitation does not appear to include or specify a requirement for the inclusion of proposal submission --- only costs or prices. Accordingly, it does not appear possible for your agency to know if any of the submitters have any experience or capabilities for te may have
Noted will be considered but not part of the source selection process.
• Recommended Selection Criteria/Process – have submitted proposals, it is strongly recommended that the primary criteria or standard for based on project-has been the case involving most of our proposal submissions, fees, costs and estimated
Noted
• Recommendation - Revise/Eliminate Requirement for Estimating/Quoting “Total Costs”
As discussed above, there is no way to predetermine or estimate individual or total costs ceptable on the basis of individual Task or Work Orders. Contract is intended to function as task orders based upon development and obtaining any and all permits that might be required.
Quali cations verview
As brief background respective of our submitting the question and recommendations ts at four Animal Disease Center, Ames, IA; CDC, Atlanta, -depth experience on projects involving pathological waste incinerators and permitting; I’m a registered Professional Engineer in 8 states; a Diplomat in the American Academy of Environmental Engineers –
Engineering and Science. Attached is a partial listing of our clients involving pathological waste incinerations and permitting as well as my CV.
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