JA_signed.pdf

CONTROL NO. 15-21

JUSTIFICATION AND APPROVAL FOR OTHER THAN FULL AND OPEN

COMPETITION

HTRW AE Services IDIQ – AMEC Environment and Infrastructure

U.S. Army Corps of Engineers, Contracting Division New England District

July 22, 2015

JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

1. CONTRACTING ACTIVITY:

The U.S. Army Corps of Engineers Contracting Office, New England Contracting District, 696 Virginia Road, Concord, MA 01742.

2. DESCRIPTION OF ACTION:

Approval is being sought for a modification to the Architect-Engineer (A-E) Indefinite Delivery Indefinite Quantity (IDIQ) Contract W912WJ-11-D-0005, to increase contract capacity perfomance from $8,568,609 to $11,568,609 and extend the duration by two years. This will allow for the incumbent A-E contractor, AMEC Environment and Infrastructure (AMEC), to complete Task Order 0004 (TO 0004), for work on the Remedial Investigation and Feasibility Study (RI/FS) at the U.S. Army Corps of Engineers (USACE) Cold Regions Research and Engineering Laboratory (CRREL) in Hanover, New Hampshire. AMEC is to perform, or provide, on a firm-fixed price basis, a wide range of environmental services associated with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) RI/FS through Decision Document in response to existing extensive contamination of the soil, groundwater and air on and abutting the CRREL property. Due to the extremely complex nature of this site, characterization of the extent of contamination and evaluation of remediation alternatives are extremely challenging while maintaining the health and safety of CRREL employees, child development center attendees, and abutters in the immediate vicinity. Public and employee outreach also requires high risk, high stress, high visibility communication on almost a daily basis. These challenges require immediate consideration of an in-scope task order modification and time extension. This Justification & Approval is intended only to authorize an increase to the overall capacity of the IDIQ contract in order to allow the New England District to modify the existing task order and allow AMEC to continue as the Engineer for this project. Stated differently, this is not a new "project" that would trigger the Brooks Act requirements, but is instead merely a J&A to authorize an increase in capacity to allow AMEC to continue working on a project for which they were already selected utilizing Brooks Act procedures.

The CRREL TO 0004 is funded with Operation and Maintenance, Army (OMA) FY 13 & 14 funds received via Military Interdepartmental Purchase Request (MIPR) through Army Environmental Command (AEC). All other existing task orders against this IDIQ contract are complete.

COMPETITION

HTRW AE Services IDIQ – AMEC Environment and Infrastructure

U.S. Army Corps of Engineers, Contracting Division New England District

July 22, 2015

The current value of the contract is $8,568,609. In order to complete the work required, an increase of $3M is required. The current Period of Performance (POP) goes through September 22, 2016. In order to take the contract through to Record of Decision, an additional two years will be required on this contract. Therefore, this is also a request to extend the POP for two years through September 22, 2018.

3. DESCRIPTION OF SUPPLIES/SERVICES OR NATURE OF CONSTRUCTION:

The IDIQ A-E contract was established to provide study, investigation, design and construction phase engineering services for Hazardous Toxic and Radioactive Waste (HTRW) sites/projects located anywhere within the boundaries of the North Atlantic Division, and other mission areas as assigned, in support of the New England District (NAE) HTRW Design Center, via competitive solicitation W912WJ-10-R-0015 . The sites may be:

a. Currently owned or controlled by the Federal Government, either military or civilian agencies.

b. Formerly Used Defense Sites (FUDS).

c. Formerly Utilized Sites Remedial Action Program (FUSRAP) sites, or

d. Other sites where the USACE is authorized to perform HTRW studies, investigations, designs, or incidental environmental remediation services in support of remedial actions and long-term operation and maintenance (O&M). Expertise required includes, but is not limited to, registered, licensed and/or certified professional engineers, scientists and surveyors.

HTRW projects performed by the Department of Defense typically must follow the CERCLA process. The following excerpts from EPA/540/G-89/004, Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA, October 1998, summarize the process:

“…the remedial investigation and feasibility study (RI/FS) process represents the methodology that the Superfund program has established for characterizing the nature and extent of risks posed by uncontrolled hazardous waste sites and for evaluating potential remedial options. This approach should be viewed as a dynamic, flexible process that can and should be tailored to specific circumstances of individual sites; it is not a rigid step-by-step approach that must be conducted identically at every site. The project manager's central responsibility is to determine how best to use the flexibility built into the process to conduct an efficient and effective RI/FS that achieves high quality results in a timely and cost-effective manner. A significant challenge project managers face

COMPETITION

HTRW AE Services IDIQ – AMEC Environment and Infrastructure

U.S. Army Corps of Engineers, Contracting Division New England District

July 22, 2015 in effectively managing an Rl/FS is the inherent uncertainties associated with the remediation of uncontrolled hazardous waste sites. These uncertainties can be numerous, ranging from potential unknowns regarding site hydrogeology and the actual extent of contamination, to the performance of treatment and engineering controls being considered as part of the remedial strategy. While these uncertainties foster a natural desire to want to know more, this desire competes with the Superfund program's mandate to perform cleanups within designated schedules.

The objective of the RI/FS process is not the unobtainable goal of removing all uncertainty, but rather to gather information sufficient to support an informed risk management decision regarding which remedy appears to be most appropriate for a given site. The appropriate level of analysis to meet this objective can only be reached through constant strategic thinking and careful planning concerning the essential data needed to reach a remedy selection decision. As hypotheses are tested and either rejected or confirmed, adjustments or choices as to the appropriate course for further investigations and analyses are required. These choices, like the remedy selection itself, involve the balancing of a wide variety of factors and the exercise of best professional judgment.” –Section 1.1

“The RI serves as the mechanism for collecting data to characterize site conditions; determine the nature of the waste; assess risk to human health and the environment; and conduct treatability testing as necessary to evaluate the potential performance and cost of the treatment technologies that are being considered. The latter also supports the design of selected remedies.

The FS continues to serve as the mechanism for the development, screening, and detailed evaluation of alternative remedial actions. It is important to note that the RI and FS are to be conducted concurrently and that data collected in the RI influence the development of remedial alternatives in the FS, which in turn affects the data needs and scope of treatability studies and additional field investigations.” –Section 1.4

“Following completion of the RI/FS, the results of the detailed analyses, when combined with the risk management judgments made by the decision-maker, become the rationale for selecting a preferred alternative and preparing the proposed plan. Therefore, the results of the detailed analysis, or more specifically the comparative analysis, should serve to highlight the relative advantages and disadvantages of each alternative so that the key tradeoffs can be identified. It will be these key tradeoffs coupled with risk management decisions that will serve as the basis for the rationale and provide a transition between the RI/FS report and the development of a proposed plan (and

COMPETITION

HTRW AE Services IDIQ – AMEC Environment and Infrastructure

U.S. Army Corps of Engineers, Contracting Division New England District

July 22, 2015 ultimately a Record of Decision (ROD)). Specific guidance for preparing proposed plans and RODs is provided in the draft guidance on preparing Superfund decision documents.” – Section 6.3

AMEC was selected for this five year IDIQ contract, which was awarded 12 January 2011, by demonstrating specialized experience, technical competence, professional qualifications, and past performance in implementing and executing all phases of HTRW projects in accordance with the RCRA/CERCLA cleanup process. This includes familiarity and experience with HTRW investigations in soil, sediment, water, and air;

human health and ecological risk assessment; feasibility study; remedial design;

remediation oversight and optimization; public outreach; and local, state, and Federal regulatory requirements associated with DOD environmental cleanup.

TO 0004 was awarded on 14 September 2011 to provide a wide range of environmental services associated with the RI/FS phase activities at CRREL. Activities include setting up and maintaining administrative record; establishing a local repository; conducting file reviews and identifying data gaps; performing independent analysis of project history and files; characterization of soil, groundwater, bedrock, and soil vapor contamination;

performing a baseline risk assessment to evaluate the current and potential future risk to human health and the environment from chemical contaminants; implementing a groundwater extraction pilot test; implementing a soil vapor extraction pilot test;

preparing implementation plans; preparing Remedial Investigation (RI) Report;

preparing Feasibility Study (FS) Report; conducting public meetings and community outreach; preparing Proposed Plan; preparing Decision Document; conducting indoor air testing; and implementing indoor air mitigation techniques to ensure facilities are safe to occupy.

The CRREL facility is approximately 30 acres in area and is located 1.5 miles north of the Town of Hanover in Grafton County, New Hampshire and 1.75 miles northeast of Norwich, Vermont (VT). CRREL consists of eleven primary buildings and other smaller support structures. Dartmouth College owns residential property adjacent to the site along CRREL’s north (demolished structures) and south (occupied structures) property boundaries. Highway 10 forms the eastern boundary of the site, and across Highway 10 from CRREL is the Frances C. Richmond Middle School and Dartmouth Printing Company. There are also two commercial structures located at the southeast border of CRREL. To the west, Dartmouth College Real Estate owns a small swath of land between CRREL and the Connecticut River on which are remains of former gravel pits, a stump dump yard and a former domestic refuse storage area.

CRREL was established in 1961 by the U.S. Army Corps of Engineers to combine the work of two predecessor organizations: (1) the Snow, Ice, and Permafrost Research

COMPETITION

HTRW AE Services IDIQ – AMEC Environment and Infrastructure

U.S. Army Corps of Engineers, Contracting Division New England District

July 22, 2015

Establishment and (2) the Arctic Construction and Frost Effects Laboratory. CRREL performs basic and applied research in snow, ice, and frozen ground, as well as providing the Army engineering research to develop equipment and procedures for applications in cold regions.

CRREL has extensive refrigeration capabilities in the Main Laboratory Building. Starting in the early 1960’s until late 1987, the Laboratory utilized trichloroethylene (TCE) as a secondary refrigerant and non-contact heat transfer fluid. The potential non-cancer and cancer-causing effects of TCE were not understood during this period. Toxicological studies soon evolved to indicate that TCE is a highly toxic solvent. In the late 1980’s, TCE use at CRREL was replaced by ethylene glycol.

During the time that TCE was in use at CRREL, some undetermined quantity (on the order of tens of thousands of gallons) of TCE was lost to the subsurface from tanks, piping and equipment. This was due to commonly accepted operating practices of the time, leaks, and accidents. Groundwater contamination at CRREL is attributed to these releases over time.

Environmental investigations and cleanup of CRREL were commenced by the Army in 1990. A total of 18 areas of concern (AOC) were identified as requiring cleanup in a draft RI report. A groundwater treatment facility was constructed to treat TCE-contaminated groundwater that was already being extracted for use as noncontact cooling water in the Main Laboratory Building. Then, in 2003, after nearly a decade of limited efforts by CRREL to evaluate soil treatment options and some degree of regulatory oversight by the New Hampshire Department of Environmental Services (NHDES), the regulatory agency, NHDES, concurred with a Remedial Action Plan (RAP) that stated no further action (NFA) was required at all AOCs except CECRL - 002, 009, 013 and 015. Three of the remaining AOCs concern TCE in soil and groundwater and the fourth AOC addresses near surface soil contamination from other compounds. The plan to address the remaining AOCs was to provide some means to stop contamination in soil from impacting groundwater, or justify why that is either unnecessary or impractical, and to provide ongoing groundwater pumping and treatment to ensure contaminated groundwater does not leave the property and impact the Connecticut River and surrounding areas. As stated in the 2003 RAP, and concurred with by NH DES, containment of groundwater contamination is being provided by the combination of existing production wells and the Groundwater Treatment Plant.

In the mid to late 2000’s, environmental professionals and regulators became more and more concerned with impacts of contamination vapors emanating from contaminated soil and groundwater and migrating into buildings, a phenomenon known as vapor

COMPETITION

HTRW AE Services IDIQ – AMEC Environment and Infrastructure

U.S. Army Corps of Engineers, Contracting Division New England District

July 22, 2015 intrusion (VI) that is especially prevalent with TCE. Therefore, CRREL began a VI investigation in 2009. Initial sampling occurred in 2010 and comprehensive VI sampling has been ongoing since to determine the extent of vapor contamination both on CRREL and at the surrounding properties. These investigations have included borehole sampling of soil gas on-post and off-post, sampling utility pathways to determine if TCE vapors have migrated off-site through these preferential pathways, and sub-slab and indoor air sampling within neighboring buildings to include small businesses, Dartmouth College Housing, and the Frances C. Richmond Middle School. These investigations and the associated risk analyses and dissemination of results to the stakeholders and public are part of services provided by AMEC under Task Order 0004.

In early FY12, CRREL and NH DES were in discussions on how to administratively close out the open AOCs. These discussions were occurring as NAE was getting up to speed on the project and gathering VI data, which determined there were indoor air concerns in a number of occupied buildings at CRREL, including the Main Lab and the Child Development Center (CDC). Therefore, three of the 18 AOCs were reopened by Army Environmental Command and placed back in the RI/FS Phase to further investigate the nature and extent of contamination in soil, groundwater and air, to further evaluate human health risks (which are now a considerable concern due to the newly discovered indoor air quality issues) and to evaluate alternatives to cleanup and protect people on and off the installation. Additionally, mitigation measures to protect employees were implemented and pilot tests for potential remedies were performed.

AMEC was tasked with the RI/FS and follow-on Proposed Plan and Decision Document.

As such, they also supported NAE with coordination and communication regarding the sampling, findings, and paths forward with CRREL leadership, staff, families of the Child Development Center (CDC), neighboring property owners and residents, middle school administration and families of school children, as well as the public. Information on the investigations continues to be shared via the internet, phone calls and meetings with neighbors to CRREL and the town, as well as at public meeting events at the Middle School. A Restoration Advisory Board (RAB) has also been established in accordance with Department of Defense (DOD) and CERCLA regulations. A RAB is a stakeholder group that meets on a regular basis to discuss environmental restoration at a specific property where DOD oversees the environmental restoration process.

Presently, AMEC continues to collect data. They are evaluating the nature, extent, and associated risks of all historic and recently collected soil, groundwater, and air data, and compiling the site history, actions taken to date, and findings in an RI report. Draft of this report is due October 5, 2015. AMEC also continues to pilot test alternatives to the present groundwater containment method, pilot test innovative soil treatment techniques, and operate, maintain and optimize indoor air mitigation methods. These studies will feed the Draft FS Report, which is due February 18, 2016. They also

COMPETITION

HTRW AE Services IDIQ – AMEC Environment and Infrastructure

U.S. Army Corps of Engineers, Contracting Division New England District

July 22, 2015 continue monitoring of indoor and subsurface air both on and off the CRREL property, which includes efforts to identify and mitigate against pathways of vapors from contaminated locations into building interiors and workspaces. State-of-the-art for vapor intrusion sample collection is typically time consuming (8-hour sample collection) and expensive and laboratory results are not available for approximately 30 days. Due to the extensive number of areas requiring sampling, and the need for “real-time” results, AMEC and NAE have collaborated to develop innovative and defensible sampling methods, which are being lauded by the top academics and practitioners dealing with VI issues. Furthermore, AMEC and NAE were the first to adopt new human health risk evaluation methodologies established by the Environmental Protection Agency (EPA) for TCE in air. Through these innovative approaches, AMEC has been key to ensuring indoor spaces can remain occupied, and they have been instrumental in the implementation of evacuation protocols when they have detected unacceptably high concentrations of TCE in the Main Laboratory building.

The present scope also includes taking the project through the RI/FS stage to the Decision Document and includes:

Project Management Maintenance of Administrative Record and File Searches Establishing a Local Repository Community Relations Support Activities Public Meetings and Restoration Advisory Board (RAB) Support Risk Assessment Work Plan Environmental Risk Assessment Human Health Risk Assessment and Screening Level ERA Sub-Slab Communication Testing Sub-Slab Vapaor Depressurization Pilot Sub-Slab Vapor Soil Vapor Investigation HVAC Investigation for Mitigation Indoor Air Vapor Sampling Portable GC/MS Site Vapor Monitoring Portable Air Purifier Deployment and Monitoring Phase I Membrane Interphase Probe Investigation Phase I Direct Push/Soil Borings Phase II Groundwater Profiler Installation of Overburden And Bedrock Wells Groundwater Treatment Pilot Testing Well Development and Sampling Main Lab SVI Alternatives Analysis

COMPETITION

HTRW AE Services IDIQ – AMEC Environment and Infrastructure

U.S. Army Corps of Engineers, Contracting Division New England District

July 22, 2015

Soil Vapor Recovery Testing Off-Post Vapor Sampling and Monitoring Soil Vapor Extraction Pilot Study with PneuLog Preparation or Remedial Investigation Resolution of Comments for RI Preparation of Feasibility Study Resolution of Comments for FS Applicable or Relevant and Appropriate Requirements (ARARS) Development Proposed Plan Resolution of Comments for Proposed Plan Decision Document

Additional required in-scope work is anticipated in the amount of $3M on Task Order 0004. Period of performance would be extended from September 2016 to September 2017. Specific tasks requiring modification include various types of studies and evaluations. Environmental investigations and response activities will be performed in accordance with applicable rules, regulations and guidelines. Typical HTRW Services may include (in no particular order) the following; however, this list is not intended to be all inclusive:

• Administrative Record Maintenance;

• Bioremediation pilot;

• Risk Assessment Biological and Human Health support;

• Emergency response and related activities;

• Environmental compliance assessments/surveys;

• Air quality monitoring, surveys and emissions reporting;

• Laboratory testing;

• Data management;

• Soil vapor extraction pilot;

• Soil/sludge stabilization pilot;

• Treatment and disposal Investigative Waste;

• Soil Washing pilot;

• Bedrock Well Installations;

• Pilot Tests for remedial Options;

• Interim Remedial Actions (IRA);

• Time Critical Remedial Actions (TCRA);

• Non Time Critical Removal Actions (NTCRA);

• Engineering Evaluations Cost Analysis (EE/CA);

• Decision Documents (DD);

• Community Relations Plans (CRP) and revisions;

• Public Meetings and Open Houses support;

COMPETITION

HTRW AE Services IDIQ – AMEC Environment and Infrastructure

U.S. Army Corps of Engineers, Contracting Division New England District

July 22, 2015

• RAB support;

• Land Use Control Evaluations;

• Vapor Intrusion Studies;

• Groundwater soil Surface water and Sediment sampling and analysis;

• On site real Time air analysis using Hapsites and associated sampling equipment;

• Off-site Response Actions.

It is critical for AMEC to perform these tasks, which are continuations of existing tasks in the high stress, high risk, atmosphere of an environmental investigation and cleanup.

Discussion and evaluation of these activities will also be included in the ongoing RI and FS reports. Having another contractor perform these activities would have significant impact on human, health and the environment as well as budget and schedule. First, the procurement activities associated with a new contract award would delay site activities, including ongoing real-time air monitoring data collection and evaluation.

Second, it would require several months for the new contractor to develop the appropriate level of institutional knowledge to adequately convey project issues and requirements to complete CERCLA documentation (RI, FS, Proposed Plan, Decision Document) and to provide clear and concise messages to stakeholders and the public in an already highly sensitive location. Third, the new contractor would not have the air sampling expertise developed specifically for the CRREL project. It would be far more advantageous to the Government for AMEC to finish data collection and pilot testing and then finalize the RI and FS, as opposed to inserting a new contractor that would be forced to maintain the current schedule as approved by the regulators, while not having AMEC’s knowledge of this complex cleanup project.

4. AUTHORITY CITED:

10 U.S.C. 2304(c)(1), Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements, as implemented by FAR 6.302-1(a)(2)(iii), for DoD, NASA, and the Coast Guard, services may be deemed to be available only from the original source in the case of follow-on contracts for the continued provision of highly specialized services when it is likely that award to any other source would result in –

(A) Substantial duplication of cost to the Government that is not expected to be recovered through competition, or

(B) Unacceptable delays in fulfilling the agency’s requirements. (See 10 U.S.C.

2304(d)(1)(B).)

COMPETITION

HTRW AE Services IDIQ – AMEC Environment and Infrastructure

U.S. Army Corps of Engineers, Contracting Division New England District

July 22, 2015

5. REASON FOR AUTHORITY CITED:

Increased capacity is proposed for A-E IDIQ Contract W912WJ-11-D-0005 because AMEC is the only source that can provide continued highly specialized services to fulfill the project requirements under TO 0004. Award to any other source would result in unacceptable delays and substantial duplication of costs that would not be recovered through competition.

(a) Project Background.

As an HTRW Design Center, NAE has always maintained a suite of HTRW A-E IDIQ contracts. The last contracts were awarded in FY11 following a competitive procurement in accordance with the Brooks Act as a Qualifications-Based Selection. Five IDIQ contracts were awarded; four small business contracts and an unrestricted contract to MACTEC Engineering and Consulting, Inc., on 12 January 2011. MACTEC was subsequently purchased by AMEC. The unrestricted contract was awarded for large, technically complex projects, often with multiple areas of concern and significant public outreach responsibilities that, based on over twenty years of historical information from relationships with A-E HTRW small business contractors, would exceed the personnel capacity and outreach capabilities of small businesses. AMEC’s contract was for one year, with four one-year options for a total potential contract capacity of $15M. Option year 1 was mistakenly not exercised prior to the completion of the base year.

Task Order 0004 however was issued on 14 September 2011 for RI/FS at CRREL, prior to the untimely exercise of the first option year. The tasks presently on Task Order 0004 include the investigations, studies, and comparative analysis necessary to complete the site wide RI/FS. Task Order 0004 also includes support for the extensive public outreach requirements for the CRREL project to include a RAB.

Portions of the RI are presently under review. The RI is scheduled for completion October 5, 2015 and the subsequent FS is scheduled for completion February 18, 2016. The FS will compare alternatives for remediating the site. This will be followed by a Proposed Plan, which will propose a remedy to stakeholders and the public. A public comment period will be held. At the completion of that period, typically 30 days, a Decision Document will be completed. This document will prescribe the remedy for the site and will be the basis for follow-on remedial design and construction. Final Decision Document is scheduled for October 27, 2016.

COMPETITION

HTRW AE Services IDIQ – AMEC Environment and Infrastructure

U.S. Army Corps of Engineers, Contracting Division New England District

July 22, 2015

(b) Justification. Multiple factors have contributed to the need to increase the contract capacity of the IDIQ contract with AMEC. Since 2011 AMEC has collected data which have continued to assist in the development of the conceptual site model. AMEC has a depth of resources experienced with this complex site: multi-disciplined staff for investigations, human health risk assessment, risk communications, data chemistry, data management, data visualization, VI investigations, TCE remediation technologies pilot testing, facility engineering for analysis of HVAC systems, and building materials. This project has multiple media types (soil, bedrock, groundwater, air). There are also several potential areas of contamination surrounding, beneath, and within occupied buildings. Investigation of hazardous waste sites is fraught with unknowns, and is, therefore, very iterative in nature, meaning that as you collect data to answer one question, several additional questions and associated data needs are identified. The CRREL project is no different. The project team, which includes AMEC under Task Order 0004, has been tasked with finding TCE deep within soil and bedrock and with determining how TCE is moving from the upland portions of the 30 acre property to the lower portions of the property to the groundwater extraction wells. Although data has helped in locating the sources of contamination, the flow paths have been much more difficult to find. In addition, as the team continues to sample for indoor and subsurface TCE vapors, new impacted areas are discovered, and the pathways to those areas and means to cut off those pathways must be discovered. Finally, treatment methodologies that have been piloted add more questions requiring additional system testing and data collection. For example, a soil vapor extraction pilot test was performed to determine if vapors could be removed out of the ground to control vapor migration as well as to serve as an approach to soil treatment. The concentrations of the vapors were far greater than the designers intended, which overwhelmed the treatment system collecting the vapors. While this may be an indication of a viable treatment and/or containment method, further testing must be carried out to determine the potential feasibility and design parameters of such a system.

Furthermore, CRREL has come to rely on AMEC and its innovative sampling methods to monitor indoor air within facilities to ensure the safety of occupants and to continue to optimize the air mitigation methods. The optimization is iterative, with the intent to have a reliable mitigation system sampling approach as part of the Decision Document.

(c) Impact. If the capacity of the contract is not raised to the proposed amount, the RI/FS Phase could not be completed by AMEC. Another A-E firm would need to complete the RI/FS, most likely under a new procurement action which would delay the Decision Document for upwards to a year beyond its present schedule

COMPETITION

HTRW AE Services IDIQ – AMEC Environment and Infrastructure

U.S. Army Corps of Engineers, Contracting Division New England District

July 22, 2015 while a new, project-specific procurement was completed, followed by an additional six months for the new A-E firm to become fully integrated into the project. In addition to learning the history, evaluating all the site data (over 10,000 samples), and getting trained on the sampling techniques developed specifically for this project, the new A-E firm would have to develop relationships with multiple stakeholders and build the trust with regulators, stakeholders and USACE that has been developed in a high stress, high risk, high visibility environment over the last three and a half years.

The CRREL site is complex because:

• The primary chemical of concern, TCE, is a dense non-aqueous phase liquid (DNAPL); it is well-recognized by environmental professionals that identifying subsurface source zone location, characterizing source geometry, and determining if DNAPL liquid is present in the subsurface are very difficult at DNAPL spill sites. Quantifying the mass of this recalcitrant compound in the environment is challenging.

• By most standards, especially relative to spill sites in the Northeast, the CRREL site is a “deep unsaturated overburden site”, which increases the costs of investigation and the difficulty in locating source zones.

• The uppermost soil layer is comprised of fine-grained lower-permeability soils, and most conventional remediation technologies do not perform well in such settings.

• Buildings at the CRREL site include interconnected sections of different age, and uncertain drainage, ventilation, and other utility piping configurations. The buildings are occupied and continue to be used for CRREL’s research mission, which means physical components and building use can change with time.

• Recent developments in diagnostic tools for rapid vapor intrusion pathway assessment (e.g., controlled pressure testing) are not practicable in buildings like those at CRREL.

The combination of these factors necessitates a deliberate, iterative, and strategic site-specific approach to assessment, monitoring, and mitigation efforts.

Indoor and outdoor air quality investigation and monitoring at the CRREL site now involve state-of-the-art, real-time vapor sampling and analyses, which can

COMPETITION

HTRW AE Services IDIQ – AMEC Environment and Infrastructure

U.S. Army Corps of Engineers, Contracting Division New England District

July 22, 2015 increase data collection, speed decision-making and response, and expand the range of monitoring and investigation opportunities. Project members are at the technical leading edge of pushing the state of the vapor intrusion practice forward.

New precedent is being set for understanding and mitigating vapor intrusion at the CRREL site.

Few sites have extensive air quality monitoring data sets comparable to the CRREL data set and dedicated state-of-the-art equipment, like that used for monitoring at CRREL, is uncommon.

This CERCLA project demonstrates the current AMEC’s breadth of experience in execution of a multi-disciplinary project at a complex site involving high resolution site characterization, vapor intrusion mitigation, time critical remedial actions, and project management for the United States Army Corps of Engineers. Their list of experienced technical personnel is deep and varied. Their understanding of the conceptual site model has been especially valuable to the U.S. Army Corps as they are able to articulate the complexities of the site with 3D visualizations.

Many different data sets are rendered in 3D and used to identify data gaps and are presented to technical personnel of varying disciplines, stakeholders, and the public. This tool allows stakeholders and public to grasping complex concepts quickly and helps build trust in the community and the CRREL workplace. It also allows for building consensus on the path forward.

As a component of a CERCLA-compliant Remedial Investigation (RI), Feasibility Study (FS) Proposed Plan (PP) and Decision Document (DD) for a U.S. Army facility with documented historical usage and multiple releases of TCE, it is critical to keep the current Army / Contractor project delivery team (PDT) in place. Since 2011 the Army / Contractor PDT has been extremely flexible to the needs of the customer and have investigated and implemented numerous complex time critical solutions at CRREL as demonstrated by the following:

Conducted seven site-wide sub-slab soil vapor/indoor air monitoring sampling and analysis events within multiple occupied buildings at the facility (twelve buildings plus outdoor sampling locations). Monitoring is conducted to evaluate worker health and safety and to monitor effectiveness of in-place mitigation systems and activities.

Collaborated with U.S. Army Corps of Engineers and scientists in the development of a response action plan designed to protect worker health and safety based in large part on the on-going soil vapor and indoor air monitoring program and CERCLA-compliant risk assessment procedures.

COMPETITION

HTRW AE Services IDIQ – AMEC Environment and Infrastructure

U.S. Army Corps of Engineers, Contracting Division New England District

July 22, 2015

Conducted soil vapor investigations to identify vapor sources and to delineate subsurface vapor impacts on-site and off-site.

Prepared numerous subsurface investigation Work Plans, Sampling and Analysis Plans, and Quality Assurance Project Plan.

Conducted a subsurface soil vapor investigation to delineate vapor impacts associated with preferential pathways associated with subsurface utilities.

Conducting real-time analysis of indoor air and soil gas using Inficon Hapsite® ER portable gas chromatograph with mass spectrometer (GC/MS).

Conduct daily monitoring of indoor air concentrations (approximately 40 samples per day).

Conducted subsurface soil vapor and indoor air sampling and analysis at off-site industrial, retail residential properties and a middle school. AMEC’s Public Outreach Coordinator collaborated with U.S. Army Corps of Engineers to plan and implement the investigations, to communicate with property owners and public officials, and communicate plans and results with stakeholders and the New Hampshire Department of Environmental Services

(NHDES).

Conducted groundwater sampling and analysis programs.

Conducted sampling of the bedrock to determine the effects of matrix diffusion.

Conducted high resolution characterization of deep subsurface contamination by utilizing membrane interface probe and hydraulic profile testing (MIP/HPT).

Data were used to refine the conceptual site model to optimize the location of soil borings, overburden and bedrock wells, and to conduct mass balance estimates for soil and groundwater.

Implemented several vapor intrusion mitigation activities including:

o Increase fresh air intake to the buildings and inspect and make recommendations for adjustments and amendments to the HVAC systems to mitigate indoor air impacts.

o Installation of Health-Mate portable air purification units in areas with impacted indoor air.

o Installation of Retro-Coat Vapor Intrusion Coating in a recently renovated portion of one building.

o Pre-design communication testing, design, and installation of a sub-slab depressurization system.

o Conducted a comparison study of sampling techniques (summa canisters, radiellos, vacuum bottles, and Hapsite portable GC) analytical results to

COMPETITION

HTRW AE Services IDIQ – AMEC Environment and Infrastructure

U.S. Army Corps of Engineers, Contracting Division New England District

July 22, 2015 identify cost effective monitoring options for both worker health and safety monitoring and meeting regulatory requirements for the RI.

o Collaborating with U.S. Army Corps of engineers and scientists to compile, evaluate, and communicate to employees, facility management, and other stakeholders the indoor air monitoring results in multiple occupied buildings at the facility.

o Continuing additional activities to identify and delineate vapor sources and vapor migration pathways at multiple locations within the facility. This includes potential migration of vapors into buildings via underground utilities as well as migration from the subsurface to outdoor (ambient) air at one former release area.

Implemented soil vapor extraction pilot to control migration of contaminated soil gas and reduce mass.

Developed, completed, and are implementing a New Community Relations Plan Initiated a new RAB program for CRREL to open lines of communication, via monthly meetings, between the Army and the Hanover community.

Reestablished and continue to maintain a CERCLA administrative record for the CRREL site and related CERCLA activities

As a result of these very unique and complex investigations and data collection activities the current Army/Contractor PDT has acquired unique knowledge about how to operate at the site, meet CRREL specific requirements and concerns to get the site through the RI/FS Phase of the CRREL project.

Any schedule delays are unacceptable to CRREL and the occupants of the facilities. There have been decades of TCE exposure that the team is getting under control. TCE exposure is cumulative, so further exposure could be detrimental to the health of the building occupants. In addition, limited exposure may be detrimental to the health of a fetus in the first trimester, so if vapor levels are not kept under control, women of child-bearing age should not be in the buildings. In addition to the potential health issues, CRREL recently completed its master plan and intends to start building new facilities on the Hanover, NH campus. This will require complete understanding of the contamination extent and integration of the treatment techniques, which typically take several years or decades. Delays in this project could severely impact the schedule of the master plan implementation.

COMPETITION

HTRW AE Services IDIQ – AMEC Environment and Infrastructure

U.S. Army Corps of Engineers, Contracting Division New England District

July 22, 2015

1) Alternatives Considered. If this Justification is not approved, any of the alternatives discussed below would be the cause of unacceptable delays to the project impacting the planned opening of the facilities and its operations.

Alternative 1 - Use of NAE In-house Resources: New England District’s personnel are very familiar with the activities to date on the CRREL RI/FS;

however, they do not have the available workload capacity to be able to complete the investigations, pilot studies, and routine sampling, as well as the RI/FS reports, in a timely and technically sufficient manner. It is anticipated that completion of these activities will require hundreds of man-days of effort, which would completely overwhelm NAE’s ability to perform and would cause significant delays to the completion of the RI, FS, and Decision Document and subsequent remediation design and construction. Additionally, NAE would have to procure drilling equipment and operators, sampling and treatment equipment, and laboratory analyses, which are resources included in the AMEC contract.

NAE is too resource-limited to meet the requirements of this project. This is not a feasible alternative.

2) Alternative 2 – Use of USACE In-house Resources from Another District: Any other district would face the same obstacles and concerns with meeting the required schedule as NAE. In addition, other districts would also have a significant learning curve, taking a minimum of six months to develop the background and skill sets necessary to familiarize itself with the project history, data collected (10,000+ data points in soil, bedrock, groundwater, soil vapor, and indoor air), pilot test designs and procedures, innovative sample collection techniques, unique site-specific human health risk assessment calculations, customer expectations, stakeholder relationships, and public outreach requirements. In addition, the district would want to revalidate collected data and risk calculations to be comfortable performing remediation alternatives analyses in the FS and final remedy selection.

New England District has reached out to NAB, which is the only other HTRW Design Center in the Region, and it has confirmed that this project is too large and too complex to perform in-house. Therefore, another district is too resource-limited to meet the requirements of this project. This is not a feasible alternative.

3) Alternative 3 – Competing a New A-E Contract: If another A-E firm could perform the ongoing RI/FS phase services, NAE estimates the delays and

COMPETITION

HTRW AE Services IDIQ – AMEC Environment and Infrastructure

U.S. Army Corps of Engineers, Contracting Division New England District

July 22, 2015 impacts associated with openly competing a new requirement would be up to approximately 12 months:

• Five months for soliciting and awarding a new A-E contract (EP 715-17, Appendix 7 indicates a typical duration for the solicitation and award of an A-E contract is 145 days) . This procurement would cost NAE approximately $150K.

• Six plus months for the awardee to develop the background and skill sets necessary to familiarize itself with the project history, data collected (10,000+ data points in soil, bedrock, groundwater, soil vapor, and indoor air), pilot test designs and procedures, innovative sample collection techniques, unique site-specific human health risk assessment calculations, customer expectations, stakeholder relationships, and public outreach requirements. In addition, the awardee would want to revalidate collected data and risk calculations to be comfortable performing remediation alternatives analyses in the FS and final remedy selection.

The team would consist of approximately eight full-time equivalents (FTE), each at approximately $250,000/year. Therefore, eight FTEs for six months would be $1M and does not include travel and per diem costs associated with site visits. This also does not account for an additional $1.2M for NAE personnel, whose typical burn-rate on the CRREL project is $100K per month.

Based on this timeline of approximately 12 months for a new A-E firm to be in a position to be able to adequately complete the RI/FS due to procurement and rework, the dates for achieving required milestones would already have been missed before the new A-E firm was fully prepared to begin work. Delays to remediation and uncertainty in sampling and reporting procedures places a potential of increased health risks to CRREL employees and the surrounding community and also delays planned master plan implementation for CRREL. Also, additional costs of approximately $2.3M would be incurred and would not be recovered through competition. This is not a feasible alternative.

4) Alternative 4 – Use of an Existing IDIQ Contract from Another District:

a) Unacceptable Delays - If another A-E firm currently under contract to another district could be awarded a task order to complete the design and to perform the construction phase services, the New England District estimates the timeframe for awarding a new task order and for

COMPETITION

HTRW AE Services IDIQ – AMEC Environment and Infrastructure

U.S. Army Corps of Engineers, Contracting Division New England District

July 22, 2015 the new A-E to be adequately familiar with the scope of work and the existing design to be up to approximately nine months:

• One month to determine current IDIQ contracts available through other districts, to determine the allowable scope of work for each IDIQ contract, to determine the available capacity remaining on each IDIQ contract, and to formally request and borrow capacity under the IDIQ contract.

• Two months for solicitation and award of a new task order including preparation of a Request for Proposal (RFP) and Statement of Work, preparation and approval of an IGE, preparation and submission of A-E firm’s proposal, preparation and approval of a Pre-Negotiations Objectives Memorandum, negotiations between representatives of the Government and the A-E firm, preparation and approval of a Post-Negotiations Memorandum, and award of the task order.

•Six months for the awardee to develop the background and skill sets necessary to familiarize itself with the project history, data collected (10,000+ data points in soil, bedrock, groundwater, soil vapor, and indoor air), pilot test designs and procedures, innovative sample collection techniques, unique site-specific human health risk assessment calculations, use of portable GC/MS for daily health monitoring, prepare all required work plans, customer expectations, stakeholder relationships, and public outreach requirements. In addition, the awardee would want to revalidate collected data and risk calculations to be comfortable performing remediation alternatives analyses in the FS and final remedy selection.

Based on this timeline of approximately 9 months for a new A-E firm to be in a position to be able to adequately complete the RI/FS due to procurement and rework, the dates for achieving required milestones would already have been missed before the new A-E firm was fully prepared to begin work. Delays to remediation and uncertainty in sampling and reporting procedures create a potential of increased health risks to CRREL employees and the surrounding community and also delays planned master plan implementation for CRREL. Also, additional costs, which would be similar in nature to Alternative 3, of approximately $2.3M would be incurred and would not be recovered through competition. This is not a feasible alternative.

COMPETITION

HTRW AE Services IDIQ – AMEC Environment and Infrastructure

U.S. Army Corps of Engineers, Contracting Division New England District

July 22, 2015

6. EFFORTS TO OBTAIN COMPETITION:

As stated in paragraph 5 above, AMEC is the only responsible source available to provide the continued highly specialized services to complete the RI/FS Phase. As described in Paragraph 5, above, a full and open competition for this action would introduce unacceptable delays in decision document, prolonging human exposure to TCE contamination, delaying master plan implementation, and also result in a substantial duplication of costs to the Government that would not be expected to be recovered through such competition.

NOTICE OF INTENT TO SOLE-SOURCE

The New England District has not published and does not intend to publish a Notice of Intent to Sole Source in accordance with FAR 5.203(a). In our view, this proposed contract action is made pursuant to the terms of an existing contract that was previously synopsized in sufficient detail to comply with the requirements in FAR 5.207 with respect to the current proposed contract action. Accordingly, the requirements for an exception under FAR 5.202(a)(11) have been met and no synopsis is currently required.

7. ACTIONS TO INCREASE COMPETITION:

As an HTRW Design Center, NAE has always maintained a suite of HTRW IDIQ A-E contracts. Historically, they have been one-year, four option years. The last contracts were awarded in FY11 following a competitive procurement in accordance with the Brooks Act as a Qualifications-Based Selection approach. NAE received 10 submissions for the unrestricted solicitation and 17 submissions to the small business solicitation. The selection resulted in contracts with the following most highly technically qualified firms;

Contractor Name

Contract Number Set Aside

Base Contract Award date

Contract Capacity

# of task orders Capacity Used

Stone Environmental

W912WJ-

11-D-0001

Small Business 30-Dec-10 $5,000,000 3 $2,120,565.40

Avatar W912WJ- 11-D-0002

Small Business (firm is an

SDVOSB)

30-Dec-10 $5,000,000 6 $3,794,343.50

Mabbett W912WJ- 11-D-0003

SDVOSB 30-Dec-10 $2,500,000 6 $1,519,928.69

COMPETITION

HTRW AE Services IDIQ – AMEC Environment and Infrastructure

U.S. Army Corps of Engineers,…