Statement Of Work- FEFO Disposal.pdf

Statement of Work for Repack and Disposal of Bis (2,2-Dinitro-2-Fluoro Ethyl) Formal in Methylene

Chloride

1. Background: Bis (2,2-Dinitro-2-Fluoro Ethyl) Formal, otherwise known as FEFO, is a plasticizer used in the creation of polymer bonded explosives such as C-4. This material was generated from the 1970s through the 1980s by Aerojet Strategic Propulsion Company, Aerojet Tactical Systems Company. It was listed as a Class A explosive, which is now Explosive 1.3. The material is in a mixture of 20/80

FEFO/Mecl2. The rest of this document will refer to the mixture as FEFO.

2. Current State: This material is currently in 20- or 30-gallon steel containers overpacked in deteriorating 55-gallon steel drums. There is vermiculite, assumed to contain asbestos, in the overpack configuration. The drums are stored in an Earthen Covered ammunition storage Magazine (ECM) on

Naval Weapons Station (NWS) Crane installation in south central Indiana. Crane Army Ammunition

Activity (CAAA) is the organization responsible for the storage and management of this material and the proponent of this project. There are approximately 41,000 pounds of FEFO, or 124 drums in a single

ECM. The pallets that the drums are banded to are severely deteriorated and mostly broken or rotted.

3. Known Hazards: There are several known hazards for this project:

• Spill – The drums are very deteriorated; spills of the outer pack and vermiculite are expected if moved.

• Hydrofluoric Acid – this is a known deterioration product of FEFO.

• Hydrochloric Acid – this is a known deterioration product of Mecl2.

• ECMs have no spill control mechanisms; drainage troughs designed for water infiltration run directly to the environment outside.

• Asbestos presence in vermiculite (We have tested, but there is no accepted test method so we must treat it as an ACM)

• Explosive 1.3 - Explosives which have a fire hazard and either a minor blast hazard or a minor projection hazard or both, but not a mass explosion hazard.

4. Scope of Work: The contractor shall plan and implement a disposal process for all the FEFO remaining at NWS Crane.

(a) Develop an asbestos abatement plan (deliverable a) and execute that plan for the vermiculite filler between the inner and outer pack of the FEFO chemical mixture.

(b) Organize and facilitate hazard classification testing. (Results: deliverable b).

(c) Provide spill containment and spill clean-up/recovery

• Develop a spill contingency plan (deliverable c).

• Provide services for all activities through disposal.

(d) Disposal of FEFO chemical mixture.

• Identify and coordinate disposal at an agreed upon, (between CAAA and Contractor), RCRA

Hazardous Waste (HW) Disposal/Treatment Facility.

• Develop a repacking plan and provide packaging information for an Interim Hazard

Classification (IHC) (deliverables d and e).

• Repack FEFO chemical mixture according to IHC and ship to the agreed upon RCRA HW

Disposal/Treatment Facility.

5. Deliverables

(a) Written asbestos abatement plan.

(b) Hazard classification testing for the FEFO mixture.

(c) Written spill contingency plan for the project.

(d) Written repackaging plan. (operation procedures)

(e) Provide packaging information for IHC

6. Work Expectations

The Contractor shall furnish all services, materials, supplies, labor, equipment, investigations, studies, superintendence, and travel as required, in connection with the performance of work described herein.

The Contractor shall comply with applicable Federal, State, and Local laws, regulations, and guidance;

and perform all work in accordance with these requirements and any applicable agreements.

The Contractor shall be responsible for obtaining and maintaining any registration or certification as required by the various Federal, State, and Local regulatory agencies, and any other registrations, certifications, licenses, permits, warrants, or other credentials or permissions required to perform the contracted tasks.

Site Conditions and Confined Space Determination: The Contractor is solely responsible for assessing all work areas, including the Earthen Covered Magazines (ECMs), to determine if they meet the definition of a Permit-Required Confined Space (PRCS) under OSHA 29 CFR 1910.146. The Contractor shall provide a written determination and rationale to the Government for review prior to commencing work. The

Contractor’s firm-fixed-price proposal shall include all potential costs for developing and implementing a compliant PRCS entry program. No additional contract value will be authorized if work areas are determined to be a PRCS after award.

Contractor shall provide a site-specific Health and Safety Plan (HASP) for Government review and concurrence prior to the start of work.

The contractor will coordinate with the CAAA Environmental office to meet all local, state, and federal regulatory requirements regarding this project. The CAAA Environmental office will inspect operations to ensure compliance with all local, state, and federal regulatory requirements. The contractor will report to the CAAA Environmental office any discovered noncompliance with the above-mentioned regulatory requirements. The contractor will designate an employee to oversee environmental compliance on the worksite and the designee will identify themselves and provide contact information to the CAAA

Environmental office.

The contractor shall be responsible for the management of any solid waste, e-waste or universal waste generated by their performance of work. Hazardous waste and asbestos containing material waste will be managed, shipped, and disposed of in coordination with the CAAA Environmental office.

The contractor must provide a list of all hazardous materials, a Safety Data Sheet (SDS) for each material, and the intended use of each material to the CAAA Environmental office prior to bringing it onto the installation. The CAAA Environmental office will provide written approval for the use of hazardous materials at the work site.

The contractor shall do everything within their power to prevent spills of any hazardous substances on the installation. This includes fuels needed for equipment and any other hazardous substances. If the contractor wishes to bring a fuel tank larger than 500 gallons onto the installation, it must first coordinate this with the CAAA Environmental office to meet Spill Prevention Control and

Countermeasures (SPCC) requirements.

The contractor will ensure that it follows requirements and regulations in the Clean Water Act (CWA) as it relates to storm water pollution. Including, but not limited to, unintended stormwater collection in

“empty” containers, the spread of contamination that is not protected from the weather, and generation of wastewater.

The contractor shall take all necessary measures to prevent pollution, minimize hazardous waste generation, and to protect the air, water, and land. This includes, but is not limited to: minimizing the emission of pollutants into the air; preventing the discharge of pollutants into any component of the drainage system or onto any paved or unpaved area; and controlling dust, noise, and other nuisances resulting from operations.

The contractor will work with CAAA Environmental to identify and impliment corrective actions needed for any noncompliance with any regulatory environmental requirements related to the contractors performance of work.

The contractor will provide deliverables to the CAAA Environmental office for review and concurrence before conducting work regarding the deliverables, specifically the plans.

The Contractor’s cost proposal shall include all costs for the work items described herein and shall fully document all assumptions made for accomplishment of all tasks described herein.

7. Training

• All workers shall have 40-hour HAZWOPER training.

• Per AR 530-1, the contractor employees must complete Level I OPSEC Awareness training. New employees must be trained within 30 calendar days of their reporting for duty and annually thereafter.

• For all contractors with security clearances. Per AR 381-12 Threat Awareness and Reporting

Program (TARP), contractor employees must receive annual TARP training by a CI agent or other trainer as specified in 2-4b.

8. AT OPSEC Requirements

• All contractor employees, to include subcontractor employees, requiring access Army installations, facilities and controlled access areas shall complete AT Level I Awareness training within 5 calendar days after contract start date or effective date of incorporation of this requirement into the contract, whichever is applicable. The contractor shall submit certificates of completion for each affected contractor employee and subcontractor employee, to the COR or to the contracting officer, if a COR is not assigned, within 30 calendar days after completion of training by all employees and subcontractor personnel. AT level I Awareness training is available at the following website: http://jko.jten.mil.

• Contractor and all associated subcontractor employees shall provide all information required for background checks to meet installation access requirements to be accomplished by installation

Provost Marshal Office, Director of Emergency Services or Security Office. Contractor workforce must comply with all personal identity verification requirements (FAR clause 52.204-9, Personal

Identity Verification of Contractor Personnel) as directed by DOD, HQDA and/or local policy. In addition to the changes otherwise authorized by the changes clause of this contract, should the

Force Protection Condition (FPCON) at any individual facility or installation change, the

Government may require changes in contractor security matters or processes.

• Contractor and all associated sub-contractors employees shall comply with adjudication standards and procedures using the National Crime Information Center Interstate Identification

Index (NCIC-III) and Terrorist Screening Database (Army Directive 2014-05/AR 190-13), applicable installation, facility and area commander installation/facility access and local security policies and procedures (provided by government representative); or, at OCONUS locations, in accordance with status of forces agreements and other theater regulations

• The contractor and all associated sub-contractors shall brief all employees on the local iWATCH

Army program (training standards provided by the requiring activity ATO). This local developed training will be used to inform employees of the types of behavior to watch for and instruct employees to report suspicious activity to the COR. This training shall be completed within 5 calendar days of contract award and within 5 calendar days of new employees commencing performance with the results reported to the COR NLT 30 calendar days after contract award.

9. Solicitation Instructions

• Include DFARS clause 252.204-7012, which requires the contractor to comply with NIST 800-171.

Also include DFARS provision 252.204-2019 into solicitations. Acquisition officials should follow procedures outlined in DFARS 204.73 and verify vendors have an adequate NIST SP 800-171 summary assessment score within the Supplier Performance Risk System (within PIEE). If the score doesn't show a medium- or high-level assessment with a score of 110 or better (as described in the "NIST SP 800-171 DoD Assessment Methodology"), include clause 252.204-7020 and obtain the vendor's "system security plan" and "plan of action" for NIST SP 800-171 verification and assurance by Army security officials.

http://jko.jten.mil/