JETFO_05_25_2025_Fair_Opportunity_Exception_Brown_and_Bryant_RA_OM_Redacted_1.pdf

consolidated in an area that is now under the RCRA-cap. The U.S. Army Corps of Engineers, on behalf of the EPA, imported clean soil material, performed grading and fencing, and constructed the RCRA-cap and basic asphalt cap over the former plant property.

A second ROD was issued and signed in 2007. The 2007 ROD addressed the A-zone groundwater, subsurface soil from the base of the A-zone groundwater to the B-zone groundwater, and the B-zone groundwater. The purpose of the 2007 ROD was to remove contaminants from the A-zone groundwater to protect the B- and C-zone groundwater, restore B-zone groundwater for potential beneficial drinking water, and prevent exposure to contaminated groundwater. The major components of the 2007 ROD included proper abandonment of the City of Arvin well, CW-1, and relocation of the well to a suitable distance from the Site contaminant plume, installation of a shallow A-zone aquifer extraction system with above ground UV oxidation water treatment and disposal of the treated water to the Arvin City POTW, groundwater monitoring of the B-zone to evaluate the effectiveness of the monitored natural attenuation (MNA) remedy, and institutional controls placed on the Site and nearby properties to limit the use of B-zone groundwater. The 2007 ROD also allowed for the temporary storage of extracted water and periodic transport off-site for treatment and disposal

The primary contaminants of concern (COCs) found at the Site are chloroform, 1,2-dibromo-3-chloropropane (DBCP), 1,2-dichloropropane (1,2-DCP), 1,3,-dichloropropane (1,3-DCP), dinoseb, ethylene dibromide (EDB) and 1,2,3-trichloropropane (1,2,3-TCP). The latest Five- Year Review, conducted in 2021, indicated that the remedy is functioning as intended for the soil and groundwater contamination. The RCRA and basic asphalt caps are preventing exposure to the contaminated soil beneath them and minimize surface water infiltration. The groundwater plume was observed to be shrinking in both the A-zone and the B-zone groundwater, indicated by the majority of the wells containing overall decreasing contaminant trends, as well as decreasing concentration trends for a majority of contaminants in the downgradient wells.

Under RAC Contract EP-S9-13-02, Task Order 029-RARA-09H2 APTIM FFS LLC, the EPA continue implementation of the Remedial Action (RA) for the Brown & Bryant Superfund Site, including the installation of an extraction system in the shallow A-zone aquifer with onsite treatment or off-site disposal of the contaminated extracted water.

Justification Summary (FAR 16.505(b)(2)(i)(B))-

The EPA has an urgent need for HDR APTIM to provide uninterrupted and continuous Remedial Action Operation and Maintenance Support (RA-O&M). The contractor currently provides RA-O&M support for the on-site extraction system which consists of three 8-inch extraction wells requiring frequent fluid pump out and P020 waste disposal under the EPA Region 9’s RAC 3 APTIM contract. The RAC 3 APTIM contract is due to expire in November of 2023.

HDR APTIM is uniquely qualified to provide continued Remedial Action Operation and Maintenance Support to the EPA during site transition to the State of California at the level of quality required for Brown and Bryant because of their historic and current work supporting the onsite remedial action-

HDR APTIM has the unique qualifications and necessary knowledge, staff, and experience to provide O&M support at the level of quality required as it currently provides the services described herein for the Brown and Bryant site. HDR APTIM has provided RA site support for Brown and Bryant since taking over from the U.S. Army Corps of Engineers in 2015.

During this time APTIM has the acquired unique technical expertise and experience in addressing the site contaminants and the Brown & Bryant groundwater plume with the technologies currently implemented at the site. At the direction of the EPA APTIM has optimized the existing GWETS Multi-phase Extraction (MPE) and Dual Phase Extraction (DPE) Equipment, installing upgraded Multi-phase Extraction (MPE) and Dual Phase Extraction (DPE) equipment onsite and authoring a GWETS O&M Manual for the onsite extraction system. APTIM has repeatedly demonstrated their vast knowledge of onsite systems and of the groundwater plume in verbal communications during meetings, and in their review of complex technical documents related to monitoring the progress of remediation of the site, including groundwater monitoring reports, and recommendations of well installations and abandonments.

The Brown and Bryant Site will need to be transitioned to the state of California within ten

(10) years of the remedy being fully functional and operating as intended (NCP, 40 CFR 300.435(f)(3)). EPA is currently in discussions with the state of California about the details of the Site transition, and the transition is currently projected to take place around EPA FY2025 late Q3 early Q4. APTIM’s unique knowledge of the existing on site MPE/DVE system and evaporation tanks, daily operations, sampling, maintenance, and data validation, will be vital to quickly transitioning the Site to the State of California.

Conclusion-

The Brown and Bryant Site is scheduled to be turned over to the State of California within ten

(10) years of the remedy being determined to be fully functional by EPA and the State of California (NCP, 40 CFR 300.435(f)(3) and 40 CFR 300.435(f)(2)). This transition is currently projected to take place around EPA FY2025 late Q3 early Q4 and any lapse in the specialized remedial action operation and maintenance support provided by HDR APTIM will greatly impact and may delay the transition.

As identified above, HDR APTIM is uniquely qualified to provide the EPA with Remedial Action Operation and Maintenance Support to the EPA during site transition to the State of California at the level of quality required for Brown and Bryant because of their historic and current work supporting the onsite remedial action, including their deep knowledge of onsite remediation system.

The EPA estimates it would take approximately two years for a new contractor to come up to speed enough to actively participate in the complex site transition process. To become familiar enough with the project to participate in the site transition, the new contractor would need to re-visit and/or re-perform work completed by APTIM resulting in duplicative costs and requiring considerable additional government funding, resources, and time. APTIM’s specialized knowledge of the groundwater plume, the current conditions of the B-Zone