ANCSE_Env_Memo 021920.pdf

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Arlington National Cemetery - Realignment of Columbia Pike
Solicitation number
693C73-21-R-000018
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About this file

This document consists of a memo from an environmental consulting firm and a related federal contract opportunity notice. The memo summarizes the results of environmental investigations at the Arlington National Cemetery Southern Expansion project site, noting the presence of asbestos-containing materials. It identifies uncertainties regarding the quantity of asbestos-impacted soils requiring disposal and the need to ensure appropriate mitigation measures are implemented during the separate Defense Access Road project.

The federal contract opportunity notice seeks proposals for the Arlington National Cemetery - Columbia Pike Realignment Project to realign roads, expand a park, construct pedestrian and bicycle facilities, and relocate utilities. Site preparation work will also be included. The project value is expected to exceed $10 million and will be split into a base schedule and optional work. Bid documents are anticipated to be issued on May 20, 2021, with proposals due on a date specified in the solicitation. Offerors must demonstrate experience on similar projects. The solicitation will be posted on SAM.gov and interested vendors must register to receive notifications.

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Text version

Hana Engineers and Consultants, LLC. • 7501 Boulder View Drive • Suite 620 • Richmond, Virginia 23225 • hanaengineers.com

February 19, 2020

Gregg Schwieterman Project Manager HNTB Corporation 2900 South Quincy Street, Suite 600 Arlington, VA 22206

Subject: Uncertainties associated with Hazardous Materials aspects of the Arlington National

Cemetery Southern Expansion (ANCSE) and Defense Access Road (DAR) Project

Dear Mr. Schwieterman, The purpose of this memo is to summarize the status of the environmental (i.e., hazardous materials) investigations related to the Arlington National Cemetery Southern Expansion (ANCSE) project and highlight some uncertainties associated with the property. Due to the status of the FOB2 property on the Federal Facilities Docket, Hana prepared an Environmental Site Inspection (SI) Report for the property in accordance with Comprehensive Environmental Response Compensation and Liability Act (CERCLA) requirements. The SI Report concluded that no remedial action was required at the FOB2 property based on future land use as part of ANC. However, this conclusion was predicated on the implementation of appropriate mitigation measures for Asbestos Containing Material (ACM) during the ANCSE Construction phase. The Virginia Department of Environmental Quality (VDEQ) Federal Facilities Section concurred with the SI Report in a letter dated December 13, 2019, which reiterated the need for appropriate mitigation measures during any excavation, grading or utility work. Hana will be assisting HNTB with the preparation of plans and specifications to identify all appropriate mitigation measures for

ANCSE.

Although the plans and specifications for ANCSE will identify appropriate mitigation measures for ANCSE, there are some uncertainties that should clarified to the project stakeholders moving forward. These uncertainties are identified and discussed below:

1. Portions of the ANCSE investigation area will be impacted by the Defense Access Road (DAR) project, which will include excavation, grading and utility installation. Since this project is a separate federal project from the ANCSE project, the plans and specifications detailing ACM mitigation measures for ANCSE are not applicable to the DAR project. However, if the DAR project does not also implement and document similar mitigation measures, this would be in violation of the concurrence letter from VDEQ and present potential regulatory issues.

Therefore, we recommend that ANC and/or USACE ensure that the DAR project receives all necessary data and reports related to this issue so that they can implement appropriate mitigation measures.

2. The quantity of ACM-impacted material requiring disposal cannot be accurately determined with the data collected to date. As the SI Report indicates, ACM is known to be buried in certain areas

Hana Engineers and Consultants, LLC. • 7501 Boulder View Drive • Suite 620 • Richmond, Virginia 23225 • hanaengineers.com of the site, primarily the eastern portion of the South Parking parcel. However, at the time the SI Report was prepared, specific areas of excavation and utility installation had not been identified. Therefore, previous sampling did not attempt to characterize material in these areas for future disposal. We believe focused sampling in areas proposed for excavation or utilities may be warranted so that material requiring off-site disposal during construction could be identified and quantified. Therefore, material requiring special disposal will not be firmly identified until the construction phase. We want to make clear that this presents great uncertainty with respect to planning for cost and schedule, as ACM material must be packaged, transported and disposed in accordance with 40 CFR Part 61, Subpart M and 9VAC20-81-620. Please note that this uncertainty also applies to the DAR project.

We wished to bring these uncertainties to your attention so that you can inform USACE and other stakeholders. We are glad to discuss these further with you and the project team.

Please contact me at 757-470-8361 or jeff.zoeckler@hanaengineers.com if you have any questions.

Sincerely, Jeff R. Zoeckler Vice President mailto:jeff.zoeckler@hanaengineers.com

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