BPM003359_Method_of_Approach_Attachment_3_A_Clear Creek.pdf
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- Attached to
- Master Agreement AZ|CTR055969
- Contract number
- CTR055969
- Issued by
- Arizona
About this file
This document is an Attachment 3-A Method Proposal from Clear Creek, a consulting firm specializing in environmental services, particularly legacy mining site remediation. The document is part of a solicitation for state and local contract work, with references to agencies including the Arizona Department of Environmental Quality (ADEQ), U.S. Forest Service, and State Historical Preservation Office (SHPO). The proposal involves potential projects in Arizona, specifically mentioning work in locations such as Tohono O'odham Nation, Globe, and Santa Cruz County, and involves clients like Freeport-McMoRan and Arizona Minerals Inc.
Clear Creek is proposing services for legacy mining projects, including legacy mining investigation, remedial investigation/feasibility studies, consulting services, and well abandonment. Their approach emphasizes comprehensive project management, including careful project manager selection based on experience and complexity, rigorous quality assurance/quality control protocols, and adaptive strategies for handling unexpected site conditions. The company demonstrates expertise in addressing challenging environmental scenarios, such as managing discharges from abandoned mine adits, conducting sediment sampling in submerged environments, and implementing passive treatment systems to meet water quality standards. Their methodology focuses on thorough site understanding, risk mitigation, and collaborative work with regulatory agencies.
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PART 3 of the Solicitation Documents Template version 7.0 (28-JAN-2020)
Attachment 3-A Page 1 of 6 3
Method Proposal (Method of Approach)
The Offeror shall provide a narrative response to each question that demonstrates their understanding of the Scope of Work requirements and describes your company’s overall method of approach for providing the service stated in this solicitation. If there is a question that is not applicable to the services required by the Scope of Work, you may mark it N/A. Responses shall be limited to one (1) page per question.
Do not include marketing materials.
Offeror Response:
Clear Creek is responding to scope of service items 5.1.1 Legacy Mining, 5.1.4 Remedial Investigation / Feasibility Study, 5.1.6 Consulting Services, and 5.1.9 Well Abandonment.
Question 1: Describe how your company selects a Project Manager for a project.
Offeror Response:
Clear Creek selects Project Managers based on experience with past projects similar in nature to the request, degree of project complexity (capability), and availability (capacity). When Clear Creek submits a proposal for a project, the project manager has already been identified based on these criteria. For most types of projects, we have several managers with appropriate experience and will base the assignment on availability. The degree of complexity is an important criterion in keeping costs down. For a complex project, a senior level manager is appropriate while a simple project might be effectively managed by a project-level manager.
Question 2: Describe how your company ensures that a project is delivered on-time, on-budget, and completed correctly the first time.
Offeror Response:
The primary mechanism for ensuring a project is delivered on time, on budget, and correctly is to set realistic schedules and budgets, in coordination with the client, so that all stakeholders are on the same page. By doing this, expectations are clear and the work is far more likely to be done correctly the first time. It is important to build time into the schedule to accommodate issues beyond our control—subcontractor schedules and property access, for example. Rushing a project to meet an unrealistic schedule can be a factor in work being done incorrectly the first time.
Another helpful strategy is compiling and tabulating data as it is received; this can save time in the report preparation stage. There is no need to wait to begin writing a report until all the data are available.
Cost control is directly linked to the work plans agreed upon with the client. During all phases of the project, we will monitor progress with the assistance of our Deltek cost accounting system. This interactive software is useful for avoiding both budget overruns and scheduling conflicts.
Finally, Clear Creek uses support staff when appropriate, and to the extent possible, to free up the technical staff for other tasks. This includes tabulating and management of data, preparation of reports, and even much of the work associated with Land and Water Use studies.
Page 2 of 6 3
Question 3: Describe your quality assurance/quality control procedures for the review and delivery of technical documents.
Clear Creek has a strict quality assurance/quality control (QA/QC) protocol regarding report review and signatories. No report goes out without at least one independent review; this is mandatory for every type of deliverable at Clear Creek. Depending on the market sector and the size of the contract, up to four reviewers may be required. We build time into the schedule to accommodate reviews.
The review process applies to scopes of work, contracts, technical memoranda, and reports.
Detailed reviews of data, including tables, are checked against the original data sources (such as laboratory reports) to ensure accuracy. When possible, we construct spreadsheets from electronic data deliverables so that data entry and human error are minimized. Figures are standardized, to the extent possible, to minimize errors.
Question 4: Describe your approach to developing a remedial design for a legacy mine site which has been determined to be degrading surface water quality under storm conditions.
Provide a project summary that exemplifies the success of your approach.
How was the success measured or quantified?
Our approach includes first obtaining all pertinent historical data from the site, such as soil and groundwater quality samples, meteorological data, geology (surface and underground, if appropriate), engineering design drawings of existing mine facilities, documentation of permits, and any communications with state or federal agencies regarding environmental issues. Next, we assess data gaps and identify how key data gaps should be addressed. We then develop a remedial design based on the data and information we reviewed and present that to ADEQ for review/approval.
For example: One of our clients owned an abandoned underground mine operation that was leaking about two gpm of acidic mine water from an adit. The first step was to understand the workings to the extent possible and stop the seepage from the adit. This was accomplished by first installing a concrete bulkhead in the lowermost adit and allowing mine water to back up into the mine workings. The bulkhead was then drilled to allow installation of a discharge pipe with a valve. Discharge from the pipe in the bulkhead was then pumped back to a shaft connected to the mine workings. This “recirculation” system stopped all discharge for a period of months during which time a passive treatment system was designed and installed. The passive system used wetlands style treatment to remove metal contamination and increase the pH of the discharge. After treatment, the water was again discharged, but discharge no longer exceeded water quality standards and was ultimately released to a nearby wash.
The success of our approach was proven by initially eliminating the discharge then designing and implementing a passive treatment system to ensure that the discharge from the underground adit no longer exceeded water quality standards.
Page 3 of 6 3
Question 5: How many legacy mine site remediation or reclamation projects has your firm led?
Describe the most challenging obstacle that your firm has encountered during the implementation of a mining remediation or reclamation project and how you resolved it.
Legacy mining projects have been a significant sector of Clear Creek’s market since the inception of our company in 1999. We have worked on literally dozens of legacy mine remediation projects. The most significant ones are described in detail in Attachment 2-A: Experience and Capacity Questionnaire and Attachment 2-A:
Supplement Project Descriptions:
• Cyprus Tohono Mine Site Groundwater Remedial Investigation and Feasibility Study, Cyprus Tohono Corporation and Freeport-McMoRan Copper & Gold, Inc., Tohono O'odham Nation, AZ
• Consulting Services, Lower Pinal Creek Water Treatment Plant, Freeport-McMoRan Miami Inc., Globe, AZ
• Aquifer Protection Permit and Voluntary Remediation Program Preparation, Arizona Minerals Inc.
(Arizona Mining, Inc.), Santa Cruz County, AZ
Challenges with mining sites always include public concerns about safety, water quality, and quality of life issues. Clear Creek is experienced in addressing the public regarding such issues and explaining risk/exposure concepts. We have presented in numerous public meetings regarding legacy mining issues on behalf of our clients.
A recent project managed by Clear Creek involved the investigation for closure of an impoundment at a mining site. Historical runoff to the pond came from a waste rock dump and the sediment was potentially impacted for metals. Sampling an 18-foot thickness of sediment covered by 10 feet of water was a challenge. Clear Creek identified the technology appropriate for sample collection and retained a contractor to do the work under our supervision. A total of 15 sediment samples were collected from six borings using a VibeCore-D coring device from a survey boat. The VibeCore-D sampler consisted of a vibrating core head with a weighted ring mounted to a linerless aluminum tube suspended from a winch on a survey boat. The borings were advanced by lowering the sampler through the water to the sediment surface and then vibrating the head to advance the tube into the sediments. The challenges of sampling in the pond were overcome by using the proper technology.
Developing and implementing a sampling strategy for submerged sediments (see photo below).
Page 4 of 6 3
Question 6: Discharging adits are often technically challenging and expensive to plug.
Describe successful alternative approaches that your firm has implemented to address these types of discharges.
Example: The client owned an abandoned underground mine operation with an adit that was leaking acidic mine water at a rate of two gallon-per-minute. Our team’s first step was to understand the workings to the extent possible and stop the seepage from the adit. This was accomplished by first installing a concrete bulkhead in the lowermost adit and allowing mine water to back up into the mine workings. The bulkhead was then drilled to allow installation of a discharge pipe with a valve. Discharge from the pipe in the bulkhead was then pumped back to a shaft connected to the mine workings. This “recirculation” system stopped all discharge for a period of months during which time a passive treatment system was designed and installed. The passive system used wetlands style treatment to remove metal contamination and increase the pH of the discharge.
After treatment, the water was again discharged but discharge no longer exceeded water quality standards and was ultimately released to a nearby wash.
The success of our approach was proven by initially eliminating the discharge then designing and implementing a passive treatment system to ensure that the discharge from the underground adit no longer exceeded water quality standards.
Question 7: During a Phase II ESA the field team comes across material not identified in the SAP, explain next steps.
Encountering a material not identified in the Sampling and Analysis Plan (SAP) is NOT an unusual scenario, and may also occur during Remedial Investigations In general, our next steps would include:
1—Secure the site and prevent access to the affected area until risks of exposure are better understood.
2—Notify the client immediately and discuss options for a possible change in scope.
3—Conduct background research on the material, identify possible sources, material properties. Interview people who may have knowledge of how and where the material was used and disposed.
4—Formulate a strategy to deal with the material. This may involve a revision to the Health and Safety Plan and the level of personal protective equipment (PPE) required.
5—Revise SAP and project cost estimate, and request/receive approval from the client.
6—Implement revised SAP.
Page 5 of 6 3
Question 8: Provide an example of performing work for one state agency but dealing with other state or local agencies that have regulatory oversight. If applicable, include the method of approach.
Clear Creek is currently working for ADEQ to stop the flow of low pH water from an old exploration corehole in Humboldt Canyon on U.S. Forest Service land. Before any excavation can be done to investigate the construction, a cultural resources inventory was conducted to meet the requirements of the Natural Historic Preservation Act, which is administered by the State Historical Preservation Office (SHPO). Clear Creek retained a qualified consultant known to SHPO with experience in the area to conduct the survey. It was approved by SHPO, allowing further investigation work to proceed.
The key element in the method of approach was allowing sufficient time in the schedule to do the cultural survey.
Question 9: Requesting Agencies may request that you to perform construction activity oversite, monitor risk & exposure to the general public during a hazardous waste remedial operation at an excavation site where the soil is contaminated with above threshold limits for various Semi-Volatile Organic Compounds (SVOCs) or other Polycyclic Aromatic Hydrocarbons (PAHs).
1) What information would you need from the requesting Agency to monitor exposure to the general public?
2) What are your means and methods of approach taken to mitigate the levels of risk and exposure?
General information would be needed to inform the field personnel on which constituents of concern may be present and at what levels.
With the knowledge of the chemicals of concern, an air monitoring device such as a photoionization detector (PID) or flame ionization detectors (FID) can be used to monitor the surrounding atmosphere of the work zone in order to determine the safety control that is needed. Engineering controls may include devices such as fans to keep the work zone safe. Administrative controls such as limiting work times in the work zone can be implemented. PPE such as air respirators may be required, depending on the concentration of constituents.
The air monitoring device can also be used in order to determine the size of the work zone and the distance that is needed to keep the general public safe.
Page 6 of 6 3
Question 10: What is your firms’ approach to a Risk Assessment?
Does this approach vary depending on the hazardous substance and/or media?
How?
NA. We are not proposing to conduct risk assessments.
Question 11: What approach does your firm take to understand a site before evaluating a potential risk?
NA. We are not proposing to conduct risk assessments.
End of Attachment 3-A
Attachment 3-A Method Proposal (Method of Approach)
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