Enhanced Fluid Recovery - VA ECHCS

Added: Sep 12, 2012 5:53 pm Modified: Sep 20, 2012 3:00 pmTrack Changes Q & A's as of 20 September 2012



Solicitation No. VA259-12-Q-0727



Short Title: Enhanced Fluid Recovery effort as described in the Corrective Action Plan - State of Colorado.



Extracts from questions posed by email:



QUESTION:



Upon further review of the SOW and related documents, we identified several discrepancies between the SOW and the January 3, 2011 CAP approval letter from OPS. Task 5.1 of the SOW requires groundwater sampling while the letter from OPS indicates that no further groundwater sampling is necessary for chemicals of concern. Please confirm whether the SOW or the CAP approval letter contains the correct information for the work effort required for this project.



The last sentence in Section 3 of the B.2 Statement of Work RFP explains that soil sampling may be required. Soil sampling is not included in the details of the SOW in Section 5.



In addition, the January 3, 2011 CAP approval letter from OPS requires only quarterly gauging and free-product measurement in 7 wells. Task 3 of the SOW specifies passive skimmer O&M in 4 of the aforementioned 7 wells. Please clarify this discrepancy also.



ANSWER:



CONTRACT SPECIALIST RESPONSE:



The intent of this SOW is to provide broad enough language to cover any contingencies that may arise during the period of performance of the contract, since things may change during that time. The requirements of the CAP (and CAP Modification) controls.



The Statement of Work states that soil sampling may be required, in case samples tested indicate that samples should be taken or any future modification of the CAP requires such sample-taking.



The CAP approval letter takes precedence and controls over general language contained within the Statement of Work.



COR RESPONSE:



The bottom line is the approved CAP (and CAP modifications) are the minimum that will be required under the contract. We've left the door open for additional sampling because you never know what will turn up and we don't want to have to stop and mod the contract just for an additional sample.



Right now the minimum is:



- Quarterly gauging and measurement (physical parameters) of wells 10, 11, 12, 15 17 18 and 19.



- Semi-annual measurement and gauging (physical parameters) of wells : MW-10, MW-11, MW-12, MW-15, MW-21, MW-22, MW-23, and MW-24 as well as sampling and analysis of these wells for TEPH



- Annual measurement and gauging (physical parameters), and sampling and analysis for TEPH of Monitoring wells MW-17, MW-18, and MW-19.



- Monthly servicing of the fluid recovery canisters - the "Keck Canisters'".





The only thing we're really waiting on to proceed with a request for no further action and site closure is the 4 consecutive quarters of no free product. The only free product noted has been in monitoring wells MW-10, MW-11, MW-12, and MW-15, and only in extremely small amounts - 1/10 to 1/100th of an inch of free product (no more that a sheen).



At that time we will need to accomplish confirmatory soil sampling (which should not be an issue) and can file a final report and request for site closure with the state. At that time too, we shall need to plan to remove the groundwater monitoring wells as required by the State Engineer's Office. It was our thought to either mod the contract at that time or go out for a new contract, but we're open to suggestions. We're also quite open to suggestions and strategies, indeed we seek these from the contractor, to obtain site closure.





As you can see, our plan was still to sample for CoC's but the State does not require it. However we may want to still sample for TEPH (petroleum) if it helps us in our efforts at the facility. [SEE LETTER BELOW ATTACHED TO MESSAGE FROM COR REGARDING THE CAP MODIFICATION.]





November 1, 2008



Mr. Larry Delin

Colorado Department of Labor and Employment

Division of Oil and Public Safety

Tower 3, Suite 610

1515 Arapahoe Street

Denver, CO 80202-2117





RE: Corrective Action Plan Addendum

Department of Veterans Affairs Medical Center, 1055 Clermont Street, Denver, Colorado

OPS Event #4271

WALSH Project Number: 5732-050





Walsh Environmental Scientists and Engineers, LLC (WALSH), on behalf of the Department of Veterans Affairs Medical Center (VAMC), respectfully submits this Corrective Action Plan (CAP) Addendum for the VA Denver Medical Center. The proposed Corrective Action Addendum consists of: 1) monthly Liquid Phase Hydrocarbons (LPH) abatement, 2) semi-annual Monitored Natural Attenuation (MNA).



Groundwater Sampling

Groundwater sampling and analysis for VAMC monitoring wells in accordance with the schedule below:



" Semiannually: The following monitoring wells shall be sampled semi-annually: MW-10, MW-11, MW-12, MW-15, MW-21, MW-22, MW-23, and MW-24.

" Annually: Monitoring wells MW-17, MW-18, and MW-19 shall be sampled annually.

" Wells shall be analyzed for BTEX and TEPH compounds. Samples shall be analyzed for MTBE if specifically required by the OPS. Sample collection and analysis shall be in accordance with EPA approved methods.



Groundwater Monitoring

Groundwater elevations and field parameters will be measured in all accessible VAMC monitoring wells during the semiannual sampling events. Field parameters that shall be collected and reported include: temperature, conductivity, pH, dissolved oxygen (DO), and oxidation-reduction potential (ORP).



LPH Abatement

Monitor and maintain the passive Keck Canister® oil skimmers installed in monitoring wells MW-10, MW-11, MW-12, and MW-15 on a monthly basis.

The proposed abatement of LPH will consist primarily of the maintaining of in-well passive skimmers in four wells along the northern and western property boundaries that are known to contain free product (MW-10, MW-11, MW-12 and MW-15). Bailing wells with free product may also be employed. Free product will be removed on an as-needed basis from the storage cells on the devices and temporarily stored in 55-gallon drums on the site. The free product will be periodically removed from the drums and disposed of at the Arvada Treatment Center, or similar facility.



Monitored Natural Attenuation is the proposed corrective action for this site, once the free product is removed. The goal of the MNA is obtain closure and a finding of No Further Action for this site.



The VA has been collecting groundwater data from this site since 1993. Groundwater at the site is generally within RBSLs, with the exception of persistent traces of free product in several wells, mainly MW-10, MW-11, MW-12 and MW-15. The following wells have been selected for periodic monitoring based on the historic data. The proposed monitoring schedule is outlined below.



Well Location in Plume Sampling Frequency Rational

MW-10 Source Semi-annual LPH present. Historically, COCs below MCLs.

MW-11 Source Semi-annual LPH present. Historically, COCs below MCLs.

MW-12 Source Semi-annual LPH present. Historically, COCs below MCLs.

MW-15 Source Semi-annual LPH present. Historically, COCs below MCLs.

MW-17 Downgradient Annual Historically, COCs below MCLs

MW-18 Downgradient Annual Historically, COCs below MCLs

MW-19 Downgradient Annual Historically, COCs below MCLs

MW-21 Midplume Semi-annual Historically, COCs below MCLs

MW-22 Downgradient Semi-annual Historically, COCs below MCLs

MW-23 Midplume Semi-annual Historically, COCs below MCLs

MW-24 Downgradient Semi-annual Historically, COCs below MCLs



Water levels will be gauged on all wells surrounding the former tank pit (in addition to the above mentioned wells, MW-8, MW-9, MW-13, MW-14, MW-16, and MW-20) using an oil/water interface probe on a semi-annual basis. Depth to water or free product will be noted as well as the thickness of any LPH. In-well passive skimmers will be repositioned if data indicates that residual free product is collecting elsewhere. Groundwater samples collected according to the above schedule will be analyzed for Benzene, Toluene, Ethylbenzene and Total Xylenes (BTEX) and Total Extractable Petroleum Hydrocarbons - diesel range organics (TEPH-DRO).



A Monitoring and Remediation Report (MRR) summarizing the findings of abatement and monitoring activities will be submitted to the OPS on a semi-annual basis.







ADDITIONAL COMMENT BY THE COR REGARDING THIS LETTER BEING THE 2010 CAP MODIFICATION:



The 2008 and 2010 are one in the same. We completed it and submitted it in 2008, the state responded in 2010….