EBAsco INTEROFFI CE CORRESPONDEN CE DATE : FROM: … · Ebasco cost increase over current WAF due to extension in project duration; currently anticipated to require approximately

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EBAsco INTEROFFICE CORRESPONDENCE

DATE November 5 1991

DOC f M91-404

Ross Gilleland

FROM Rick Gleasotif-~ SUBJECT ARCS I - EPA CONTRACT NO 68-W9-0034

WORX ASSIGNMENT NO ll-1RJ4 PINETTES SALVAGE YARD - RA ALTERNATIVES FOR COMPLETION OF RA

INTRQOUCTION

As you arbull aware Ebasco has been aonitoring progress on the Extrakaol coaponent of the Pinetteamp Salvage RA and we have grown i ncreaainqly concerned about the lack of progress on thh critical part of thbull work aaaigruaent In the light of current s tatus of the Extrakaol fabrication wa have initiated actions to evaluate alternatives to Extrakaol for reaediation of Pinetteamp soil containirtg 5-50 ppm PCS This memo presents a conceptual evaluation leading to a recoue nded set of activities to r esolve the direction of thbull RA relative to treatment or disposa l of 5-50 ppm PCB bulloil Pleaae note that the alternatives and general cost iapacta preaented are intended to apply priaarily to the 5-50 ppm PCB aoil c oaponent of the RA Furthermore costs are preaented as order of aaqnitude estibullates and a r e inte nded to be utilized tor c oaparative purposes and not as funding estimat es

I On Augubullt 30 1991 Ebasco held a meeting with Sevenson Environbullenta l Services and their lower tier Solvent Extraction vendor CET to discuss the delinquent soil treatment component ot the Pinetteamp Salvage RA and to pursue a Correct ive Action Plan (CAP) frobull Sevenson to address this component Savenson presented a CAP to Ebaaco on September 6 1991 which identified a series of redeaign fabrication and testing activities leading to inal testing of the Extraksol STS unit on December 14 1991 This was to be allowed by winterization in preparation or a Hay 11 1992 delivery o the unit to Pinetteamp site

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Ross Gilleland November 5 199 1 Page 2

In accordance with an Ebasco-EPA meeting on September 17 1991 Ebasco notified Sevenson t hat they would be allowed to proceed with the CAP but that we would monitor progress to determine viability of the Plan to meet the goals of the RA While Sevenson has attempted to be responsive to the CAP the status of the Extraksol system has worsened significantly In early September limited progress was made by CET on mechanical testing a nd pursuit of a permit to test the unit with solvent loaded however no progress has been made on critical engineering or fabrication aspects of the project

The progressive deterioration of the Extraksol situation appears to be a result of corporate confusion a nd an apparent lack of commitment by CET or its Australian parent company to continue the Extraksol project the Pinetteamp Salvage RA or its related contractual obli9ations The current information available to Ebaaco throu9h Sevenson h that CE T has no intent to complete the Extraksol unit and the company i t self may be so l d off in whole or in part by its parent corpor a t ion The current situation has been chronicled in sevensons weekly CAP reports which have been i ncluded in Ebaacobulls weekly status reports to EPA These reports should be referenced for more detail

ALTERHATIVE EVAWATIQN

As described above the STS fabrication delinquency has reached the point where Ebaaco has 9rave concerns about our ability t o complete the Reaedial Ac tion un less preparations are aade to implement an alternative to Extraksol This llerno presents and evaluates several alternatives as follows

1) Maintain current contract posture and await resolution of Extrakaol

2) Retain Sevenson and specify alternative technologyvendor a) alternative solvent extraction vendor (RC CBEST) b) alternative technology (Galaon llPEG) c) offaite landfill

3) Terminate Sevenson contract and reprocure

1) Maintain currant contract posture and await resolytion of Extrok1ol holdups - Thia is effectively a no-action alternative Resolution of the Extraksol holdup will occur either if a) CET recouitbull to the completion of the project as ita corporate responaibility 1 or b) CET sells off Extraksol and the Pinette amp subcontract and another party coapletea fabrication and Pinettes operations

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Ross Gilleland November 5 1991 Page J

Based on the prior project record the likelihood of CET meeting its project commitments i n the near term appears nil There fore the most likely opportunity for Extraksol is through its sale to or takeover by another party Sevenson has indicated that only one party has surfaced (Sevenson has not identified this conridential party) and that the likelihood of a buyouttakeover will be clarified by midshyNovellber Reportedly a meeting is scheduled between cET and the potential buyer durinq the weak of November 4

Extraksol recovery and application to Pinette s would present minimal requirements to alter technical specifications

minimal impact to subcontract cost

ainibullizes need to reevaluate subcontract s ubmi ttalbull

requires no ROD revisions by EPA

Di11dy1ntogas

prolonged uncertainty precludeamp forward progreas while awdting resolution 1992 completion is becomin9 increaain9ly unlikely

increaain9 unlikelihood of viability of Extraksol

buyout takeover the best hope for Extrakaol recovery bullay beco- encullbered by legal acquisition iaauea cauain9 prolonged delays

CoatScbadula Iapacta

week for week slip in anticipated delivery of unit to site due to inoperability and thereforbull aasuaed untas tability of unit in winter currant status approxiaately four weeks behind CAP schedule implies aidshyJuna bullobilization and bullid-OCtober 1992 completion Asauaing no possible le9al resolution prior to end of 1991 project would likely extend to 1993

possible aubcontract coat increase subject to negotiation of auppleaental agreement ainiaal increase currently anticipated to be justitied by Ebasco

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Ross Gilleland November 5 1991 Page 4

Ebasco cost increase over current WAF due to extension in project duration currently anticipated to require approximately 3000 LOE hours $275000 (Ebasco costs on ly) assuming construction activities resume and carry through 1992 construction season higher it project extends to 1993 due to prolonged lack ot resolution

2) Retain Sayenson ond specify p lternatiye yeodor - This alternative maintains sevenson as the contractor of record and avoids or bullinimizes potentially time-consuming or costly Ebasco procurement activities or design modifications which would be required if Ebasco were to terminat e the Sevenson contrac t a nd reprocure working with and through the Sevenson subcontract t o identity options a nd obtain technical proposals is the lllOBt expedient and least disruptive mechanism to proceed with RA completion Ebasco has already induced Sevenson to i nitiate colllblunications with alternative vendors and to provide initial feedback on the following options

2a) Util 1H alt1rgatiy1 Solyent Extraction yendor - Sevenson habull obtained initial information on alternative Solvent Extraction vendors Ebasco has independently checked the atatua and potential availability of these vendors

RC C - Rc c has a pilot scale unit which is currently operative on a New York project and the BEST process has been deaonstrated on PCB contabull inated soil including a Pinetteamp treatability bull bullbullplbull in 1990 Rcc does not currently have a corcial full-Hlbull unit for application to Pinetteamp Rcc waa recently purchased by Halliburton within the last fev 110ntha Halliburton has reportedly approved a $6- lOH capital bud9et for fabrication of a full-scale unit on spec i n 1992 However a pplication of the BEST process at Pinettebull would require near-i-edia t e co-itaent to proceed with fabrication RCC has indicated a strong interest to seve naon and would anticipate fabrication of a one ton per hour unit Realistically while significant 1992 onsite proqreaa la reasonable completion of the RA might extend to the 1993 season Coat for BEST would likely be approximately equal to or sobullewhat hi9her than the c urrent Extrakaol costs of approximately ~ton (co11poaite of all soil treatmentshyrelated coatbull)

C F Systems - C F Syatebulla recently purc hased by Morr ison-Knudsen is also lacking a full-scale mobile couercial unit and has not debullonstrated its capability to treat Pinetteamp soils While a CFS representative has expressed interest in the Pinettes opportunity fabrication

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Ross Gilleland November 5 1991 Page 5

and cost are major obstacles to a Pinettes application CFS currently purports to plan building a 10 ton hour skid-mounted unit tor the United creosote Supe rfund site for a first quarter 1993 start but this unit would not be available for Pinetteamp until approximately first quarter 1995 CFS would be prepared to design and fabricate a 2-5 tonhour unit for Pinetteamp but cost would be projected at approximately -ton

Other Solvent Extraction technologies - Two other projects one by ENSR and another by ART Inc (Low Energy Extraction Process LEEP) are in bench- or pilot-scale developmental stages These projects are not advanced enough to be considered available in the foreseeable future for the Pinettes RA

eased on the above information RCCBEST appears to be the only near-term viable potentially cost-and time-effective alternative to Extraksol

aaintaina Solvent Extraction technology avoidbull need for ROD reviaion or aodification of design specificationbull

pi11dy1ntage1

no conuaercial unit requires repeat of STS fabrication proceaa with attendant bullchedule uncertainties requires deonatrated corporate co-itbullent to up-front capital expenditure

CobulltJSchtdule Iapacta middot

probable delay ot RA cobullpletion into 1993 construction

potential cost increase to accommodate new lower tier subcontractor although order of magnitude costs for treatment would be anticipated to be approxhately equal to current costs

Ebasco cost middotincrease current WAF due to reprocurementsubcontract activities review of bullubbullittals extension in project duration bullagnitude uncertain without proposed SevensonRCC schedule but likely on order of 5000 LOE hours$425000 (Ebasco costs only)

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Ross Gilleland November 5 1991 Page G

2b) Utilize alternate treatment tec hnoloay - dgchlorination ~ - Dechlorination as represented by Galsons l(PEG process was given significant attention in both the 1989 Feasibility Study and ROD At the time it received a less favorable evaluation than Solvent Extraction as it was not well-tested or demonstrated and no commerchl unit had either ~een designed or tested However Sevenson has entered into substantial discussions with Galson representatives and reports that Galson is currently demonstrating a mobile coJIUllercial unit at the Industrial Transformer site in Hous ton Texas and would be prepared to commit to the Pinetteamp Salvage RA for the 1992 season It has been purported by Galson that their KPEG unit could perform Pinetteamp soil treatment over a five month duration including mobilization and demobilization which would allow a 1992 completion of the RA sevenson currently projects costs to be approximately equal to current subcontract soil treatment costs

There reaain technical uncertainties regarding the proven ability of this technology to treat contatDinated soils s uch as those at Pinetteamp Ebasco would expect SevensonGalson to debullonatrate treatability success prior to comJllitbullent to this alternative Because this alternative would deviate from the current ROD and design apecitications EPA would have to either a-nd the ROD or prepare an Explanation of Significant Difference and Ebaaco would need to modify sections of the specifications relating to soil treatment Ebasco would require and review a new set of soil treatment submittalamp and the project would then proceed according to a revised project schedule

retains onaite permanent destructive alternative treatbullent technology as a principal remedial element

technology and equipment are purportedly commercially available and proven avoiding fabrication uncertainties

pi andyontagea

Technical uncertainty of ability of the technology to aeet project cleanup objectives no treatability deaonstration yet completed for Pinettes site

deviation frobull Solvent Extraction would require ROD and design bulloditications

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Ross Gilleland November 5 1991 Page 7

CostSchedule Impacts

potential 1992 RA completion

subcontract costs uncertain without detailed proposal costs assumed to be approximately equal to current soil treatment costs

Ebasco cost increase over current WAF to support reprocurementsubcontract activities design modifications sub11lttal review extension in project duration magnitude uncertain pending receipt and evaluation of SevensonGalson schedule but likely on order of 5000 LOE hours$425000 (Ebasco costs only)

2c) Specity ottslte landfill - Otfsite landtilling was considered in the 1989 FS a nd ROD but was distavored due to its failure to bulleat the CERCLA NCP preference for permanent destructive remedies This alternative continues to conflict with the statut ory preference however it rebull ains the potentially aost expedient and leas t costly approach to cobullpletion of the RA The current subcontract includes a price for offaite secure landtilling of c learing and grubbing debris or concrete at $430 ton and $440ton respectively Inclusion of approxiately 3000 tons of 5-50 ppa PCB soil would require a r e negotiation of price and could result in a price decrease however for purposes of this evaluation the current contract price suggests a potential decrease of $150000 in subcontract cost relative t o the current Solvent Extraction coat Additionally upon securing a couitment frobull landfilling facilities for the soil quantities RA activitiH would be liaited only by the rate of excavation and shipaent of soils the r efore RA cobullpletion would be a certainty in 1992 and likely would be attained up t o two months earlier than the onsite treatment best case

Because offaite landfilling would be a significant deviation from the ROD and design specificatiops EPA would have to either amend the ROD or prepare an Explanation of Significant Difference and Ebasco would need to delete or modify sections of the specifications relating to soil treatment or offsite transportation and disposal respectively Following limited subcontract renegotiation and liaited submittal review the RA would resume in Spring 1992 according to a revised project schedule

amplYlnll9ll

aost expedient and least costly approach to RA coapletion

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Qisectjdyontages

aigniticant ROD dev iatio n and reversion to offsite destructive remedy

deviation from design specitications

CostSchedula Impacts

1992 RA completion earliest and most controllable of alternatives

subcontract costs uncertain without contract renegotiation likely no increase due to this component and probable reduction in overall subcontract cost

Ebasco cost increase over current WAF to support subcontract and design modification submittal review extension of project duration into 1992 magnitude uncertain pending receipt and evaluation of Sevenson revised schedule but likely on order of 3500 LOE hours $300000 (Ebasco costs only)

T1gin1t1 s1y1n1on 1ubcgntract and reprocure - Termination of the Sevenaon aubcontract and reprocurebullant (of Solvent Extraction or other approaches detailed above) is considered to be the aoat costly and lengthiest approach to coapletion of the Pinettebull RA Termination for convenience would entitle Sevenaon to seek compensation for their costs associated with the termination and might therefore entail significant additional co1t1 to the governaent Such coats could be avoided by a bullteraination for default however because the current probleas are largely a result of lower tier subcontractor probleas beyond Sevensons control it is by no meana certain that a default of the Sevenson contract is justified Therefore default would likely generate substantial legal-related costs

3)

Furthermore termination of the Sevenson contract would suspend 1ite operations and conditions at their current status with no certainty that a replacement subcontractor would be in place to resuae project activities at the start of the 1992 field construction season Ebasco would expend considerable effort to close out the sevenson contract to revi1e De1ign s pecifications to aatch current site conditions and to prepare and issue an RFP and evaluate new proposals Following evaluation and EPA consent to award Ebasco would repeat aubmittal reviews leading to issuance of a notice-toshyproceed to a new subcontractor Collectively these

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Ross Gilleland November 5 1991 Page 9

activities would repeat a substantial part of those conducted under w A No OJ-1Rl4 and the current W A and yet these actions would result in no specific advantage over the options available as presented in alternatives 2a-c 1 except to remove Savenson from the RA In fact there is no assurance that any replacement subcontrac tor would perform better than Sevenson nor is there any certainty that new subcontracted costs would be as low as current costs Realistically the reproc ure11ent option would be unlikely to allow completion of the RA in 1992 and would result in substantially higher costs to EPA than any of the 2a-c alternatives

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Di11dya ntages

bull ubs t a ntial fi nancial and le9al exposure by t eninationdefault

d iarupta RA activi t y and continuity with probable ai9nificant 9ap in site control

o ffe r s no bullerita over alternat ives 2a-c but results i n s ubs t antial coat and schedul e growth

Coat Scb1dull Iaoacta

1992 RA cobullpl1t ion unlikely for treatment options bull arq i nal for offdt e disposal

au~ontract costs uncertain but likely to increase

Ebaaco coats to terminate current contract revise design specifications r1procure re-evaluate proposals review aubaittala and issue new notice-to-proceed would be substantial added to costs to support extended project duration described in alternatives 2a-c would likely result doubling of costs noted above (ie approximately 6000-8000 LOE hours $600000 - Ebasco coats only)

RECOMMENDATIONS

In consideration of the evaluat ion f ac t ors di s cussed above Ebasco reco-enda the followi ng course of act ion to advance th1 Pi netteamp RA

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1) Ebasco and EPA s hould take an active position to identify and procure an alternative to Extraksol A prolonged wait-and-see posture will waste time which could be effectively utilized to resolve the approach to treatment a nd disposal of 5-50 ppm PCB soils to allow early resumption of related site activities in 1992

2) Ebaaco recommends against termination of the Savenson contract for reasons described above Rather Ebasco recommends that sevenson be requested to submit detached proposals for a) replacement of Extraksol with BEST b) replaceaent of Extraksol by Galson s KPEG process and c) substitution of otfsite landfilling for onsite treatment sevenson should respond with technical cost and schedule information for each alternative complete with lowershytier subcontractor commitments and in the case ot Galson results of a treatability demonstration on 5-50 ppm soils This proposal process may require 3-4 weeks for SC1wenaon to respond During this time EPA can plan and iaplaaent actions in preparation for a possible ROD

~ aaendment or Explanation of Significant Difference

3) Following receipt of proposal information Ebasco would review and prepare reco-endations for EPA consideration sevanbullon and its vendors would be requested to make prebullentations of the alternative approaches in order to allow a direct question-and-answer evaluation of the aerits and potential pitfalls of each approach At this tibullbull a tinal evaluation of the evolved status of Extrakbullol would be made to determine its merits versus the other alternatives

4) EPA and Ebaaco would finalize selection of the approach tor RA coapletion and Ebasco would specify such to sevenbullon

5) Ebasco and Sevenson would complete negotiation of a supplemental subcontract agreement A contract moditication would be prepared and submitted to EPA for consent

This process would require approximately 4-6 weeks to reach the selection of the alternative approach and approxiaately 2 additional weeks to complete the contract modification process Ideally EPA could proceed with the public not ice aspects of the possible change in selected remedy while Sevenson was preparing proposals such that the ROD could be modified to correspond with EPAEbascos selection and specification to Sevenson

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Ross Gilleland November 5 1991 Page 11

It should be noted that Ebasco is currently completing outstanding engineering and contract administration activities to support the conclusion of 1991 construction however additional activities in support of the above process are not i ncluded in the current RA Work Plan I au99a11t that EPA and Ebaaco meet as soon as possible to discuss the approach presented herein This will allow Ebasco to prepare a forecast of the activities schedule and budget required to support the project through attainment of a supplemental agreement with Sevenson Later after the receipt of alternative proposals and formulation of the agreement Ebasco will be able to prepare a Work Plan amendment addressing the technical activities schedule and budget to support completion of the remainder of the RA

Pleaae call me with any questions or comments at your earliest convbullnience Upon concurrence with EPA Ebasco will take appropriate action to obtain the detailed information from Sevenson described above -en RJG-c =

N Banakian = H Kelley L Sdjido P Gaffney w Pencola J Lowrey c Arnold

PILI PRA 101 PK 13

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