Attachment 1_Performance Work Statement.pdf

Performance Work Statement

Remediation of Soils Operable Unit

Luckey Site Luckey, Ohio

JUNE 2020

FORMERLY UTILIZED SITES REMEDIAL ACTION PROGRAM

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Luckey FUSRAP Site

Remediation of Soils Operable Unit Contract W912P420R0004 iii June 2020

TABLE OF CONTENTS

1.0 GENERAL

1.1 Contract Award

1.2 Scope of Work

2.0 STATUTORY AUTHORITY, REGULATORY COMPLIANCE, and

ADMINISTRATIVE RECORD

2.1 Statutory Authority

2.2 Regulatory Compliance

2.3 Administrative Record

2.4 Stakeholders

3.0 SITE BACKGROUND

3.1 Site Location and Description

3.2 Previous Site Operations, Structures, Material Handling and Disposal Activities

3.2.1 Previous Site Operations

3.2.2 Buildings and Ancillary Structures

3.2.3 Material Handling and Disposal Activities

3.3 Previous Investigations

4.0 SITE CONDITIONS

4.1 Topography and Drainage

4.2 Geology and Hydrogeology

4.2.1 Geology

4.2.2 Soils

4.2.3 Bedrock

4.2.4 Hydrogeology

4.3 Constituents of Concern

4.3.1 Selected Remedy

4.3.2 Cleanup Goals

4.3.3 Contaminated Areas/Media

4.3.4 Organic Contaminants

5.0 Current Remedial Action

5.1 Work Plans

Remediation of Soils Operable Unit Contract W912P420R0004 iv June 2020

5.2 Mobilization and Infrastructure Construction

5.3 Remedial Action

5.3.1 Soil Excavation and Transportation

5.3.2 Water Treatment

5.3.3 Health and Safety Monitoring

5.3.4 Contamination Control Monitoring

5.3.5 On-site Laboratory

5.3.6 Other Activities

6.0 REMEDIATION ACTIVITIES

6.1 Task 1 - Mobilization

6.2 Tasks 2a through 2f – Soil Remediation

6.3 Tasks 3a through 3f – Transportation and Disposal

6.4 Task 4 - Demobilization

6.5 Optional Tasks 5a through 5g – Building Deconstruction and Waste Transportation/Disposal

7.0 Remediation Requirements

7.1 Task 1 - Mobilization

7.1.1 Mobilization and Preparatory Work (331XX01)

7.2 Tasks 2A Through 2f – Soil Remediation

7.2.1 Monitoring, Sampling, Testing, and Analysis (331XX02)

7.2.2 Site Work (331XX03)

7.2.3 Surface Water Collection and Control (331XX05)

7.2.4 Solids Collection and Containment (331XX08)

7.2.5 Liquids/Sediments/Sludges Collection and Containment (331XX09)

7.2.6 Disposal (331XX19)

7.2.7 Site Restoration (331XX20)

7.2.8 General Requirements (331XX22)

7.3 Tasks 3A Through 3f – Transportation and Disposal

7.3.1 Disposal (331XX19)

7.4 Task 4 – Demobilization

7.4.1 Demobilization (331XX21)

Remediation of Soils Operable Unit Contract W912P420R0004 v June 2020

7.5 Optional Tasks 5A Through 5F – Building Deconstruction and Waste Transportation/Disposal

7.5.1 Mobilization and Preparatory Work (331XX01)

7.5.2 Drums/Tanks/Structures/Miscellaneous Demolition and Removal (331XX10)

7.5.3 Disposal (331XX19)

8.0 CONTRACTOR PROJECT STAFF ORGANIZATION, QUALIFICATIONS, AND

RESPONSIBILITIES

8.1 Key Individuals, Qualifications, and Responsibilities

8.1.1 Program Manager

8.1.2 Project Manager

8.1.3 Site Superintendent

8.1.4 Safety and Health Manager

8.1.5 Site Safety and Health Officer (SSHO)

8.1.6 Radiation Safety Officer (RSO)

8.1.7 Construction Quality Control System Manager (CQCSM)

8.1.8 Waste Manager

8.1.9 Project Chemist

8.1.10 Project Scheduler

9.0 RESIDENT MANAGEMENT SYSTEM

10.0 DELIVERABLES AND SUBMITTALS

10.1 General Requirements

10.2 Independent Technical Review

10.3 Data

10.4 Contractor Submittal Procedures

11.0 GREEN AND SUSTAINABLE REMEDIATION AND INNOVATIVE

TECHNOLOGIES

12.0 PUBLIC AFFAIRS

13.0 REAL ESTATE RIGHTS

14.0 PAYMENT REQUESTS

15.0 REFERENCES

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APPENDICES

Appendix A Figures Figure 1 Site Location Map Figure 2 Site Infrastructure Figure 3 Topographic Survey (1 of 2) Figure 3 Topographic Survey (2 of 2) Figure 4 Remediation Work Area Boundaries and the Modeled Depth of FUSRAP

Contaminated Soils/Fill/Debris

Appendix B Guide Specifications Section 01 01 01 REAL ESTATE Section 01 32 01.00 10 PROJECT SCHEDULE Section 01 33 00 SUBMITTAL PROCEDURES Section 01 35 13.43 10 SPECIAL PROJECT PROCEDURES Section 01 35 26 GOVERNMENTAL SAFETY REQUIREMENTS Section 01 35 29.13 HEALTH SAFETY & EMERGENCY RESPONSE

PROCEDURES FOR CONTAMINATED SITES

Section 01 35 45 CHEMICAL DATA QUALITY CONTROL Section 01 45 00.00 10 QUALITY CONTROL Section 01 45 00.15 10 RESIDENT MANAGEMENT SYSTEM CONTRACTOR MODE

(RMS CM)

Section 01 50 00 TEMPORARY CONSTRUCTION FACILITIES AND

CONTROLS

Section 01 57 23 TEMPORARY STORM WATER POLLUTION CONTROL Section 01 58 00 PROJECT IDENTIFICATION Section 02 32 00 SUBSURFACE DRILLING, SAMPLING, AND TESTING Section 02 41 00 DECONSTRUCTION Section 02 61 13 EXCAVATION AND HANDLING OF CONTAMINATED

MATERIAL

Section 02 81 00 TRANSPORTATION AND DISPOSAL OF HAZARDOUS

MATERIALS

Section 02 82 00 ASBESTOS REMEDIATION Section 02 83 00 LEAD REMEDIATION

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Section 02 84 33 REMOVAL AND DISPOSAL OF POLYCHLORINATED BIPHENYLS (PCBs)

Section 31 11 00 CLEARING AND GRUBBING Section 32 92 19 SEEDING Section 33 51 39 MONITORING WELLS

Appendix C Work Plans, Interim Change Notices, and Standard Operating Procedures

PLN-5500

PLN-5501

PLN-5503

PLN-5504

PLN-5506

PLN-5507

PLN-5508

PLN-5509

PLN-5510

PLN-5511

PLN-5512

PLN-5513

Work Plans (2017) Site Operations Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project (2016) Accident Prevention Plan/Site Safety and Health Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project (2019) Uniform Federal Policy Quality Assurance Project Plan/Sampling and Analysis Plan for the Luckey FUSRAP Site Remediation Project Luckey, Ohio (2016) Regulatory Compliance Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project (2018) Water Management Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project (2018) Waste Management, Transportation, and Disposal Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project (2017) Final Status Survey Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project (2018) Contamination Control Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project (2019) Backfill and Restoration Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project (2019) Stormwater Pollution Prevention Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project (2016) Chronic Beryllium Disease Prevention Program for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project (2016) Radiation Protection Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project

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PLN-5514 (2018) U.S. Environmental Protection Agency Tier I Qualified Facility SPCC Plan

Interim Change Notices ICN 001 Applies to PLN-5506 ICN 001 Applies to PLN-5507 ICN 002 Applies to PLN-5506 ICN 003 Applies to PLN-5506 _____ Protocol for Waste Transportation – Winter Weather

Standard Operating Procedures SOP #1 Cost and Schedule Reporting SOP #2 Negative Exposure Assessment Report to Downgrade PPE for

Specific Activity SOP #3 Exposure Assessment Report to Establish Control Zones SOP #4 Visitor Documentation Requirements

ATTACHMENTS

Attachment 1 Supporting Information

1.1 Contaminated Soil Volume Estimate Summary

1.2 Beryllium Exposure Standard Variance Letter

1.3 Historical Drawings

1.4 Parking Lot/Entrance Paving Recommendations

Attachment 2 ERPIMS Data Format Dictionary Attachment 3 Submittal Summary Attachment 4 HTRW Remedial Action Work Breakdown Structure and Data Dictionary Attachment 5 Decision Framework for Incorporation of Green and Sustainable Practices into Environmental Remediation Projects Attachment 6 Progress Payment Checklist Attachment 7 Bid Schedule

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ACRONYMS AND ABBREVIATIONS

AASHTO American Association of State Highway and Transportation Officials ACGIH American Conference of Governmental Industrial Hygienists ACM asbestos containing material AE Architect – Engineer AEC (U.S.) Atomic Energy Commission AEIC Association of Edison Illuminating Companies AF actual finish AGC (U.S.) Army Geospatial Center AHA activity hazard analysis AHAS Asbestos Hazardous Abatement Specialist AHAW Asbestos Hazardous Abatement Worker AHRI Air Conditioning, Heating and Refrigeration Institute AIHA American Industrial Hygiene Association amsl above mean sea level ANSI American National Standards Institute API American Petroleum Institute APP accident prevention plan AS actual start ASME American Society of Mechanical Engineers ASSP American Society of Safety Professionals ASTM American Society of Testing and Materials AWP aerial work platform

BRP backfill and restoration plan BBC Brush Beryllium Company BCY bank cubic yard(s) BeLPT beryllium-induced lymphocyte proliferation test bgs below ground surface BMP Best Management Practices BIHA baseline inventory and hazard assessment

CADD computer aided design and drafting CBDPP Chronic Beryllium Disease Prevention Program CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CELRB Corps of Engineers Buffalo District CFR Code of Federal Regulations CGA Compressed Gas Association

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CHP Certified Health Physicist CIH Certified Industrial Hygienist CLIN contract line item number CM Construction Manager cm/sec centimeters per second COCs constituents of concern COR Contracting Officer’s Representative CP competent person CPFF cost plus fixed-fee CPM critical path method CQC Contractor’s quality control CQM construction quality management CRZ contamination reduction zone CSP Certified Safety Professional CVAA cold vapor atomic absorption CY cubic yard(s)

DCAA Defense Contract Audit Agency DCGL derived concentration guideline level DCGLEMC derived concentration guideline level (elevated measurement comparison) D&D decontamination and decommissioning DFARS Defense Federal Acquisition Regulation Supplement DOD (U.S.) Department of Defense DOE (U.S.) Department of Energy DOR Designer of record DOT (U.S.) Department of Transportation DPT direct push technology DQCR Daily Quality Control Report DQO data quality objective

EA exposure assessment EDD electronic data deliverable EDMS environmental data management system ER Engineer Regulation ELAP Environmental Laboratory Accreditation Program elev elevation EM Engineer Manual EPCRA Emergency Preparedness Community Right-to-Know

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ERPIMS Environmental Restoration Program Information Management System EZ exclusion zone

FDGC Federal Geographic Data Committee FFP firm-fixed price FIO for information only FSP field sampling plan FSS final status survey ft foot (feet) ft2 square feet ft/day feet per day FUSRAP Formerly Utilized Sites Remedial Action Program g gram GC/ECD gas chromatography/electron capture detector GC/MS gas chromatography/mass spectroscopy GFE Government furnished equipment GIS geographic information system gpm gallons per minute GPS global positioning system GSR Green and Sustainable Remediation GWS gamma walkover survey

HEPA high efficiency particulate air HLI Hayes Lemmerz International, Inc.

HP health physics HTRW hazardous, toxic and radioactive waste

IATA International Air Transportation Association IAW in accordance with ICN interim change notice ICP/MS inductively coupled plasma/mass spectroscopy IDIQ Indefinite Delivery/Indefinite Quantity IEEE Institute of Electrical and Electronics Engineers IH industrial hygiene IPR Industrial Properties Recovery, Inc.

IPS initial project schedule ISEA International Safety Equipment Association ISO International Organization for Standardization

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IT Innovative Technologies ITR independent technical review

LBP lead-based paint lbs pounds LCS laboratory control sample LHE load handling equipment LIBS laser-induced breakdown spectroscopy low-vol low-volume

MARLAP Multi-Agency Radiological Laboratory Analytical Protocols Manual MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual MDC minimum detectable concentration MED Manhattan Engineer District mg/kg milligrams per kilogram mg/m3 milligrams per cubic meter MHE material handling equipment MIS Management Information System mrem/yr millirems per year MS matrix spike MSD matrix spike duplicate

NAD North American Datum NARA (U.S.) National Archives and Records Administration NAVD North American Vertical Datum of 1988 NCP National Oil and Hazardous Substances Pollution Contingency Plan NEA negative exposure assessment NELAC National Environmental Laboratory Accreditation Conference NEMA National Electrical Manufacturer’s Association NESHAP National Emission Standards for Hazardous Air Pollutants NFPA National Fire Protection Association NIOSH National Institute for Occupational Safety and Health NIST National Institute of Science and Technology NPDES National Pollutant Discharge Elimination System NRC (U.S.) Nuclear Regulatory Commission NTP notice to proceed NVLAP National Voluntary Laboratory Accreditation Program

OACSIM Office of the Assistant Secretary for Installation Management

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OCR optical character recognition ODNR Ohio Department of Natural Resources OD original duration ODH Ohio Department of Health ODS ozone depleting substance OEL occupational exposure level OEW Ordnance Explosive Waste Ohio EPA Ohio Environmental Protection Agency O&M operation and maintenance ORNL Oak Ridge National Laboratory OSH Occupational Safety and Health OSHA Occupational Safety and Health Administration OU operable unit

PBZ personal breathing zone PCBs polychlorinated biphenyls pCi picocurie pCi/g picocuries per gram pdf portable document format PDM precedence diagram method PEL permissible exposure limit PLC programmable logic controller PMP Project Management Professional PPE personal protective equipment ppm parts per million PQP privately qualified person psi pounds per square inch PWS performance work statement

QA quality assurance QAPP quality assurance project plan QC quality control QCS Quality Control System QP qualified person QSM Quality Systems Manual

Ra radium Ra226 radium 226

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RCP regulatory compliance plan RCRA Resource Conservation and Recovery Act RI remedial investigation RMS Resident Management System RO reverse osmosis ROD record of decision RPD relative percent difference RPP radiation protection plan RSO Radiation Safety Officer

SAP sampling and analysis plan SD submittal description SDEF standard data exchange format SDG sample delivery group SDSFIE Spatial Data Standard for Facilities, Infrastructure and Environment SDS safety data sheet sec second SHM Safety and Health Manager SLP standard lift plan SOH safety and occupational health SOP standard operating procedure SOR sum of the ratios SPCC spill prevention, control, and countermeasures SPT Standard Penetration Test SSHO Site Safety and Health Officer SSHP site safety and health plan SVOCs semi-volatile organic compounds SWPPP storm water pollution prevention plan SZ support zone

TEM transmission electron microscopy TENORM technologically enhanced naturally occurring radioactive material Th thorium Th230 thorium 230 TIA Telecommunications Industry Association toc top of casing TRPH total recoverable petroleum hydrocarbons TWA time weighted average

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T&D transportation and disposal

U uranium U234 uranium 234 U238 uranium 238 Utotal total uranium UFGS Unified Facilities Guide Specification UL Underwriter’s Laboratories USACE U.S. Army Corps of Engineers USDA U.S. Department of Agriculture USDOL U.S. Department of Labor USEPA U.S. Environmental Protection Agency USGS U.S. Geological Survey

VOCs volatile organic compounds VUI volume uncertainty investigation

WAC waste acceptance criteria WBS work breakdown structure WMTDP waste management, transportation, and disposal plan WMP water management plan WRS Wilcoxon Rank Sum WWPPP waste water pollution prevention plan WWTP waste water treatment plant

XRF X-ray fluorescence yr year µg/m3 micrograms per cubic meter

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1.0 GENERAL

1.1 CONTRACT AWARD

The United States Army Corps of Engineers (USACE) intends to award a five-year Type C contract to remediate the Luckey site in Luckey, Wood County, Ohio. The site is included in the government’s Formerly Utilized Sites Remedial Action Program (FUSRAP). The Contract will include a five-year base period and one five-year option period. The contract will be procured as a set aside for small business.

1.2 SCOPE OF WORK

This performance work statement (PWS) identifies environmental activities needed to remediate FUSRAP-contaminated soils, sediment, fill, and debris at Luckey site in accordance with the Record of Decision for Soils Operable Unit (USACE 2006). Contaminated media and waste types encountered at the Luckey Site are summarized in sections 3.2.3 and 4.3.

The selected contractor will be required to furnish all labor, materials, equipment, technical services, and supervision that include, but are not limited to:

• Updates to site-specific work plans and other required pre-construction submittals.

• Mobilization and set-up of construction equipment and facilities.

• Site infrastructure upgrades.

• Operation of an on-site laboratory.

• Collection, treatment, and discharge of stormwater.

• Operation and maintenance of on-site water treatment systems.

• Excavation and off-site disposal of contaminated soil, sediment, fill, and debris (hereafter

“contaminated soils”).

• Building deconstruction and off-site disposal of debris.

• Confirmation sampling and final status surveys of remediated areas.

• Industrial hygiene/health and safety monitoring of site workers.

• Contamination control monitoring.

• Engineering, surveying, and quality control inspections/monitoring.

• Development, operation, and maintenance of an electronic file sharing system and database that is compatible with the USACE Information Technology network.

• Assisting with preparation for and participation at public meetings.

• Restoration of excavated areas, material handling areas, and support zones.

This PWS requires the selected contractor to consult and provide technical support services to USACE throughout the remedial action. Expertise is required in the following areas:

• Beryllium monitoring and worker safety.

• Health physics.

• Installation, operation, and maintenance of permanent and mobile air monitoring stations.

• Environmental laboratory operations.

• Water treatment system design, operation, and maintenance.

• Database programming and maintenance.

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• Waste classification, manifesting, and shipping.

• Hazardous material surveys.

• Building deconstruction and debris disposal.

Work elements described in this PWS use the USACE hazardous, toxic, and radioactive waste (HTRW) remedial action work breakdown structure (WBS). Standard descriptions for the WBS elements are provided in Attachment 4.

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2.0 STATUTORY AUTHORITY, REGULATORY COMPLIANCE, AND

ADMINISTRATIVE RECORD

2.1 STATUTORY AUTHORITY

USACE is the lead federal agency for this remedial action and has overall responsibility for execution of the project in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and its implementing regulations found in the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), Title 40 of the Code of Federal Regulations (CFR) Part 300.

2.2 REGULATORY COMPLIANCE

Comply with all federal, state, and local regulations while performing work under this contract.

The selected contractor will be responsible for any non-conformance resulting from the actions or directions of their employees or subcontractor’s employees.

2.3 ADMINISTRATIVE RECORD

The administrative record file for the Luckey Site is available at the following locations.

U.S. Army Corps of Engineers 1776 Niagara Street Buffalo, New York 14207 Luckey Public Library 228 Main Street Luckey, Ohio 43443

Remedial action work plans and principal investigation reports are also available at https://www.lrb.usace.army.mil/Missions/HTRW/FUSRAP/Luckey-Site/.

2.4 STAKEHOLDERS

Principal stakeholders are listed below.

• Property owner, Industrial Properties Recovery, LLC

• Ohio Environmental Protection Agency (Ohio EPA)

• Ohio Department of Health (ODH)

• State of Ohio o Honorable Mike DeWine, Governor o Honorable Theresa Gavarone, State Senate, 2nd District

• Wood County Commissioners

• Wood County Board of Health

• Township of Troy

• Village of Luckey o Honorable Cory D. Panning, Mayor

• Federal Government o Honorable Robert Latta, U.S. House of Representatives, 5th District o Honorable Sherrod Brown , U.S. Senate o Honorable Rob Portman , U.S. Senate https://www.lrb.usace.army.mil/Missions/HTRW/FUSRAP/Luckey-Site/

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• U.S. Environmental Protection Agency (USEPA), Region 5

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3.0 SITE BACKGROUND

3.1 SITE LOCATION AND DESCRIPTION

The site is located at 21200 Luckey Road, northwest of the Village of Luckey in Wood County, Ohio. The Village of Luckey is 22 miles southwest of Toledo, Ohio (Figure 1). The site encompasses approximately 40 acres and contains a large production building and warehouse, two abandoned railroad spurs, and several smaller process and support buildings (Figure 2). The site is bordered by Luckey Road to the west, Gilbert Road to the south, abandoned railroad tracks to the east, and private farmland to the north. The surrounding area west, north, and east of the site is primarily residential farmland. The site was used for beryllium processing in support of the national defense program. Atomic Energy Commission (AEC)-related production activities and operations occurred at the site from 1949 to 1961. Beryl ore (beryllium aluminum silicate), scrap metal, and radiologically contaminated scrap metal were brought to the site during this period.

3.2 PREVIOUS SITE OPERATIONS, STRUCTURES, MATERIAL HANDLING AND DISPOSAL

ACTIVITIES

3.2.1 Previous Site Operations

A magnesium production facility was built in 1942 on U.S. Government land at the site. The facility was operated for the U.S. Government by National Lead during World War II until 1945.

In 1949, the AEC built a beryllium production facility that was operated by Brush Beryllium Company (BBC), which later became Brush Wellman. The facility produced beryllium oxide, beryllium hydroxide, and beryllium pebbles that were shipped to other facilities for further processing. The Luckey site facilities were owned by the AEC and operated by BBC from 1949 to 1958. During non-peak use of the facilities, BBC leased portions of the plant for commercial uses.

In late 1951 and early 1952, the AEC sent approximately 1,000 tons of radiologically contaminated scrap metal to the site in anticipation of resuming magnesium production. The scrap metal, which contained radioactivity levels within guidelines at the time, was stored at the site and never used for its intended purpose. Records also indicate that beryllium scrap from other AEC operations was sent to the site that might have been radiologically contaminated.

BBC operated the facility until 1958 when beryllium production ceased. Sintering and powder blending operations, established at the Luckey facility in 1957, continued until 1960.

In 1961 the General Services Administration sold the site to the privately-owned Aluminum and Magnesium, Inc., with the government retaining access rights in order to remove any remaining beryllium ore. Luckey Industries, Inc. purchased the facility in 1962, hoping to reclaim magnesium from World War II incendiary bombs. The reclamation process was unsuccessful and the property reverted back to Aluminum and Magnesium, Inc. The facility was then used to recover zinc from byproducts of the steel industry. Aluminum and Magnesium, Inc., transferred the property to its parent company, the Vulcan Materials Company, in 1967.

The Goodyear Tire and Rubber Company purchased the site in 1968 and began producing automotive foam seating and other urethane products. In 1983 the Motor Wheel Company leased the property from Goodyear, later purchasing it in 1988. Motor Wheel used the site to

Remediation of Soils Operable Unit Contract W912P420R0004

6 June 2020 coat steel automotive steering wheels with polyurethane foam and to manufacture other automotive products. Hayes Lemmerz International, Inc., (HLI) was the successor company to Motor Wheel. From 1995 to 2004 HLI leased about 23 acres of the site to Uretech International, Inc., which manufactured urethane parts for the automotive, sporting goods, and health care industries.

In 2006 HLI sold the property to Industrial Properties Recovery LLC (IPR), an industrial scrapping business. Shortly after purchase, IPR began demolishing buildings including a former Production Annex. During December 2006, the ODH issued an Emergency Adjudication Order to IPR to cease demolition of buildings and handling of any radioactive material.

The Wood County Combined General Health District deemed the site a public health and safety concern and the Wood County Court issued an injunction against IPR during June 2009. The injunction requires IPR to either demolish or make necessary repairs to site structures and salvage or properly dispose of all debris, rubbish, and garbage. IPR resumed demolition and salvage activities during late 2013, but was stopped again when ODH issued another Emergency Adjudication Order in December 2013. Site facilities are not currently being used.

3.2.2 Buildings and Ancillary Structures

There are several large buildings and smaller structures at the site that were built to house or support magnesium production activities and subsequently used during beryllium processing and sintering activities (Refer to Attachment 1.3 – Historical Drawings).

Large Buildings

• Production building

• Production annex

• Melting, alloying and shipping building

• Laboratory building

• Maintenance office building

• Main office

• Employee activity building Small Structures

• Pump house (for fire protection water)

• East and west well houses

• Guard house

• Shack

• Sewage treatment plant

3.2.3 Material Handling and Disposal Activities

Documented material handling and disposal areas at the site include:

• Lagoons that received beryllium processing sludges.

• Waste disposal pits located in the eastern section of the site.

• A diked disposal area located in the northeast section of the site.

• A sewage treatment plant.

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• Material handling areas adjacent to railroad sidings and production buildings.

• Scrap metal storage areas.

• Spoils areas in the vicinity of the sewage treatment plant.

• A settling basin for solids produced from softening of extracted ground water.

3.3 PREVIOUS INVESTIGATIONS

Previous site investigations and surveys are summarized below.

• Oak Ridge National Laboratory (ORNL 1990) – preliminary radiological survey and sampling/analysis of soil and surface water samples.

• U.S. Department of Energy (DOE 1996) – preliminary site evaluation of beryllium and radionuclide contamination detected during the ORNL survey.

• USACE 1998 – wetlands designation survey.

• USACE 2000 – remedial investigation (RI) that consisted of:

o Gamma walkover surveys o Laser-induced breakdown spectroscopy (LIBS) survey of soil for beryllium contamination o Geophysical surveys o Sampling and analysis of background soil, sediment, surface water and air o Sampling and analysis of off-site surface water, sediment, and groundwater o Sampling and analysis of on-site soil, sediment, surface water, groundwater o Sampling and analysis of building dust, structures and ambient air

• USACE 2011 –volume uncertainty investigation (VUI) that consisted of:

o Topographic survey o Geophysical surveys o Gamma walkover surveys o Exploratory trenching, sampling, and analysis of soil and sediment from underground utility locations o Sampling and analysis of site soil and groundwater

• Annual groundwater monitoring.

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4.0 SITE CONDITIONS

4.1 TOPOGRAPHY AND DRAINAGE

Topography surrounding the Luckey site is flat and consists of low surface gradients that slope toward Lake Erie at a rate of approximately 3 to 4 feet (ft) per mile. Surface elevations at the site and vicinity range from approximately 663 to 637 ft above mean sea level (amsl) (Figure 3).

The site is generally higher in areas where past disposal and material handling activities were conducted. These areas include lagoons, a dosing chamber, the northeast corner of the site, and debris piles east and southeast of sewage treatment plant sand filters.

Site drainage is provided by a network of ditches. Local agricultural fields are drained by tiles that discharge into the drainage ditches. Toussaint Creek is located approximately 1,100 ft north of the site and receives discharge from ditches that originate on site. The creek flows east and is generally bordered by farm fields.

Surface drainage features at the site include several National Pollutant Discharge Elimination System (NPDES) outfalls, storm sewers, and drainage ditches. Drainage from on-site sources flows to two main channels, one located in the southwest section of the site (west drainage ditch) and one located in the central section of the site (main drainage ditch). The west drainage ditch flows northward along Luckey Road, between the road and property fence line, and discharges to Toussaint Creek. The main drainage ditch originates near the former melting, alloying, and shipping building and Lagoon D. Water within the ditch flows north and discharges to Toussaint Creek.

4.2 GEOLOGY AND HYDROGEOLOGY

4.2.1 Geology

The site is located within a glacial lake plain and sits on a mantle of unconsolidated deposits (overburden) that overlie relatively flat-lying sedimentary bedrock. The unconsolidated deposits consist of soils formed from the weathering of fine textured glacial tills that contain discontinuous or sporadic thin sand and gravel lenses. Sand and gravel deposits also occur immediately above the bedrock. At the site, the overburden ranges from 15 to 26 ft thick and gradually increases to the north.

4.2.2 Soils

Predominant soils in the area are clays of the Hoytville series, which are very poorly drained, dark colored soils formed from fine-grained, gritty till on broad flats. Most native soils on the site consist of the Hoytville clay, while a section near the southeast corner contains the Hoytville clay loam (USACE 2000b). These soils are almost identical, except for slight variations in the clay content. Surface infiltration on Hoytville soils is poor. Most soils at the site are classified as lean clay with some fine sand and silt. Geotechnical data associated with samples collected during the RI and VUI is available in the administrative record and USACE website.

4.2.3 Bedrock

The Lockport Dolomite is the uppermost bedrock formation at the site and ranges in thickness from 125 to 475 ft. The Lockport Dolomite is massive in structure, open to vesicular in texture, Remediation of Soils Operable Unit Contract W912P420R0004

9 June 2020 light gray to bluish gray, and granular or crystalline. It consists mainly of calcium-magnesium carbonate.

4.2.4 Hydrogeology

Two water-bearing units are present in the vicinity of the site within the unconsolidated overburden (upper water bearing unit) and the Lockport Dolomite (bedrock aquifer). The upper water bearing unit consists of sand and gravel lenses within the till. A weathered detrital or broken rock zone also typically occurs above more competent bedrock. The bedrock aquifer is described as a good to excellent producer with typical yields of 10 to 20 gallons per minute (gpm) that can reach 100 to 500 gpm (Smith and Sabol 1994). Water- bearing zones within the bedrock occur along joints, fractures, and solution openings.

Monitoring wells installed at the site were completed in the unconsolidated overburden (S wells), the top 10 ft of bedrock (I wells), or greater than 20 ft below the top of bedrock (B wells).

Monitoring well construction details are provided in Appendix B (Section 33 51 39). Hydraulic conductivity data and historical water level data are available in the RI report.

4.3 CONSTITUENTS OF CONCERN

FUSRAP constituents of concern (COCs) at the site consist of beryllium, lead, radium-226 (Ra226), thorium-230 (Th230), uranium-234 (U234) and uranium-238 (U238). Lead was identified as a COC because lead oxide was used as an additive in the beryllium production process.

4.3.1 Selected Remedy

The selected remedy identified in the record of decision (ROD) for soils operable unit (OU) consisted of contaminated soils excavation and off-site disposal. Impacted soils would be excavated to a achieve cleanup goals for unrestricted use by the critical group (subsistence farmer).

4.3.2 Cleanup Goals

Clean-up goals for beryllium and lead in soil are target concentrations that represent the 95 percent upper confidence limit of the mean of AEC-related COCs that may remain (USACE 2017).

Cleanup goals for radionuclides in soil represent activity levels above site average background activity corresponding to a total effective dose equivalent to 25 millirems/year (mrem/yr). If a mixture of radionuclides is present, the sum of the ratios (SOR) applies per “Multi Agency Radiation Survey and Site Investigation Manual” (MARSSIM) and the ratio should not exceed unity (DOD 2000). The 25 mrem/yr soil cleanup goal for unrestricted use (subsistence farmer) for the Luckey Site yields the following SOR equation:

𝑆𝑆𝑆𝑆𝑆𝑆 =

𝑆𝑆𝑅𝑅226

2.0 𝑝𝑝𝑝𝑝𝑝𝑝/𝑔𝑔

𝑇𝑇ℎ230

5.8 𝑝𝑝𝑝𝑝𝑝𝑝/𝑔𝑔

𝑈𝑈236

26 𝑝𝑝𝑝𝑝𝑝𝑝/𝑔𝑔

𝑈𝑈238

26 𝑝𝑝𝑝𝑝𝑝𝑝/𝑔𝑔

Where:

SOR = sum of ratios Ra226 = net Ra226 concentrations above average background (1.75 picocuries per gram [pCi/g])

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Th230 = net Th230 concentrations above average background (2.11 pCi/g) U234 = net U234 concentrations above average background (1.48 pCi/g) U238 = net U238 concentrations above average background (1.63 pCi/g)

Table 1 identifies Luckey Site cleanup goals.

Table 1: Luckey Site Soil Cleanup Goals

COC Cleanup Goal

Beryllium 131 mg/kg Lead 400 mg/kg Ra226 2.0 pCi/g Th230 5.8 pCi/g U234 26 pCi/g U238 26 pCi/g

Notes:

mg/kg milligrams per kilogram pCi/g picocuries per gram

Site characterization data and historical operations records indicate that radioactive contaminants in site soil are technologically enhanced naturally occurring radioactive material (TENORM).

4.3.3 Contaminated Areas/Media

The extent of FUSRAP contaminated soils is illustrated on Figure 4. FUSRAP contaminated soils are located in areas that correspond to previous disposal activities, material handling activities, and sediment transported by site drainage features that exceed the cleanup goals.

4.3.3.1 Lagoons

Four lagoons (labeled A, B, C, and D) were used at the site. They were formed by constructing embankments with scraped soil and lining the structures with compacted clay. Lagoon A was approximately 3 to 4 ft deep. Lagoon B was constructed in two stages; the first stage was built in 1949 and was approximately 3 to 4 ft deep, the second stage was built in 1950 and was approximately 5 to 6 ft deep. Lagoon C was 1½ ft deep and also constructed in two stages.

Lagoons A, B, and C received beryllium process waters and were used to precipitate solids. The supernatant liquid was discharged to the main drainage ditch. This activity was conducted under a permit from ODH. Lagoon D was used for storm water detention.

Most lagoon sludges were removed at plant closing (1959) and placed in a diked disposal area that was constructed in the northeast corner of the site. After closure, the lagoon dikes and embankments were used to fill the lagoons. A two-ft thick clay cap was installed on Lagoons A and B in 1988. FUSRAP contamination in the former lagoons is currently being remediated.

4.3.3.2 Disposal Pits/Diked Disposal Areas

Two scrap disposal pits (Trenches 2 and 7) were confirmed at the site. Trench 7 (approximate 150 ft by 12 ft surface area) was located between two railroad spurs in the east central portion of

Remediation of Soils Operable Unit Contract W912P420R0004

11 June 2020 the site. Trench 2 was located in the northeast corner of the site (approximate 250 ft by 90 ft surface area), adjacent to the east fence. The pits were reportedly dug to a depth of approximately 6 ft and completed in native clay soils. Soil from the excavations was used as cover after they were full (Cline 1990).

Soil boring logs and an exploratory trench indicate that fill consisting of steel and fiberboard drums, metal, wood, brick, black sand, and glass fragments was encountered to a depth of approximately 12 ft below ground surface (bgs). Soil borings drilled in the vicinity of Trench 2 identified a black or gray sludge to a depth of approximately 8 ft bgs.

An approximate 2-acre diked disposal area was built in the northeast corner of the site at plant closing. The disposal area was approximately 2 ft deep and constructed with a clay bottom.

Sludges from lagoons A, B, and C were reportedly placed in the disposal area (Cline 1990).

Historical drawings (Attachment 1.3) identify the approximate locations and features of the disposal pits, diked disposal area, and appurtenances.

FUSRAP contaminated soils are present at 13 ft bgs in the vicinity of Trench 7. FUSRAP contamination is also present in soils within the northeast corner of the site (an area of approximately 3.8 acres) where the diked disposal area and Trench 2. Contaminated soils in this area occur from the ground surface to 20 ft bgs.

4.3.3.3 Sewage Treatment Plant

A sewage treatment plant was located north of the production building. The plant received only sanitary wastes (not process wastes) and contained the structures listed below. Sewage treatment plant drawings are provided in Attachment 1.3.

• Septic tank

• Pump room and wet well

• Aeration tank and settling tank

• 2,000-gallon dosing tank

• Sand filters

Buried fill has been confirmed in Trench 5, which is northeast of the sand filters. Soil borings drilled in this area identified fill between approximately 3 and 6½ ft bgs that consists of metal debris, wood, ash, brick, woven fabric, black sand, and glass fragments. Contaminated soils are present to depths of 10 and 15 ft bgs.

Contaminated soils are also present south, east and west of the sewage treatment plant in areas associated with previous material handling/storage activities. They are described below.

4.3.3.4 Material Handling/Storage Areas

Beryl ore arrived at the site in bags and drums and was stored on both sides of railroad sidings, on runways adjacent to the production building, and in the vicinity of the sewage treatment plant sand filter beds. FUSRAP contaminated soil within these areas occurs primarily from ground surface to 5 ft bgs, occasionally reaching depths of up to 10 ft bgs.

Approximately 1,000 tons of radioactive scrap metal from the Lake Ontario Storage Area (New York State) was brought to the site in 1951 and 1952 for use in a magnesium reduction process, which never occurred. The scrap metal was stored north of the production building. The

Remediation of Soils Operable Unit Contract W912P420R0004

12 June 2020 approximate locations of these storage areas are illustrated on historical documents provided in Attachment 1.3.

Debris piles that are remnants of ore staging and disposal activities are located south and east of the sewage treatment plant sand filters. FUSRAP contaminated soil in these areas is present primarily from the ground surface to 5 ft bgs. The contamination extends to 10 ft bgs in areas east and southeast of the sand filters.

West of the sewage treatment plant is a bare spot/stressed vegetation area that contains FUSRAP contaminated soils from ground surface to depths of between 5 ft bgs and 10 ft bgs.

Two water supply wells (east well and west well) are located north of the production buildings.

Both are open bedrock wells that penetrate the Lockport Dolomite. Steel casing was used in the well construction to seal off the unconsolidated overburden. Solids from water softening processes associated with the pumping of these wells were stored in the northwest corner of the site. A single, isolated exceedance of lead has been documented in this area.

4.3.3.5 Buildings

Previous surveys and analyses conducted to investigate the potential for FUSRAP contaminants within the on-site buildings included a radiological survey, beryllium and radionuclide swipe surveys, and analysis of bulk dust samples. Results are summarized below and described in the RI report (USACE 2000b).

• Radiation surveys identified several areas within the production annex (now demolished) and two isolated areas in the production building that contained activity above Nuclear Regulatory Commission (NRC) surface contamination guidelines for release to the public. The majority of these areas were in the building’s structural components (i.e.

beams).

• Beryllium swipe samples identified removable contamination in the production annex (now demolished), production building, laboratory, and maintenance office building.

Lower concentrations of beryllium were also identified in the former melting, alloying and shipping building, shack, east/west extraction well buildings, fire pump house, guard house, production annex, sewage treatment plant pump house, and employee activity building.

• Bulk dust samples contained beryllium at concentrations that were interpreted to indicate that there is a potential to exceed the USACE occupational exposure limit of 0.2 micrograms per cubic meter (µg/m3) and action level of 0.1 µg/m3 if dust is re-suspended during intrusive activities.

• Buildings that contain significant concentrations of beryllium within the construction materials (paint, brick, and concrete) include the former laboratory, maintenance building, production building, and production annex (now demolished).

Elevated beryllium has also been detected in subsurface soil samples collected adjacent to and beneath the production annex. The extent of contaminated soil beneath the buildings has not been fully delineated. Demolition and scrapping activities have been performed since the RI.

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4.3.3.6 Underground Utilities

FUSRAP contamination has been identified in manholes and in soil surrounding underground utility lines.

• Sediment from within a manhole (MH09) located west of the melting, alloying and shipping building contained beryllium above the cleanup goal.

• Sediment from within a manhole (MH11) east of the sewage treatment plant contained beryllium above the cleanup goal.

• Soil surrounding an underground utility line in the vicinity of lagoons B and C contained beryllium and radionuclides above the cleanup goals.

4.3.3.7 Drainage Ditches

FUSRAP contaminated sediment is present within and adjacent to the main drainage ditch on the site and north of the property boundary (Figure 4). The contamination occurs within the upper 1 ft of sediment/soil within the ditch and on the bank immediately east of the ditch. The contaminated sediment/soil east of the ditch may represent materials that were previously excavated from the ditch.

4.3.4 Organic Contaminants

Organic contaminants have been detected in site soils during the RI. The concentrations and locations/depths of these compounds in soil are identified in the RI report (USACE 2000b) and are summarized below.

• Three volatile organic compounds (VOCs), dichloromethane, toluene, and xylenes (total), were widely detected in site soils during the RI.

• Various semi-volatile organic compounds (SVOCs) were detected near a former underground storage tank and sewage treatment plant filter beds.

• Total recoverable petroleum hydrocarbons (TRPH) were detected in soil samples collected from a former oil pump house.

• SVOCs, TRPH, and polychlorinated biphenyls (PCBs) were detected in soil samples from a former transformer room.

• PCBs were detected in soil samples from a former electrical substation.

VOCs, SVOCs, TRPH, and PCBs are not FUSRAP COCs and the extent of this soil remedial action is not determined by these contaminants or by other contaminants that may be present at the site.

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5.0 CURRENT REMEDIAL ACTION

A contract for remediation of the soils OU was issued in July 2015. The remediation is ongoing.

5.1 WORK PLANS

The following work plans were prepared to guide the remedial action:

• Site Operations Plan (PLN-5500)

• Action Prevention Plan/Site Safety and Health Plan (PLN-5501)

• Contractor Quality Control Plan (PLN-5502)

• Uniform Federal Policy Quality Assurance Project Plan/Sampling and Analysis Plan

(PLN-5503)

• Regulatory Compliance Plan (PLN-5504)

• Water Management Plan (PLN-5506)

• Waste Management, Transportation, and Disposal Plan (PLN-5507)

• Final Status Survey Plan (PLN-5508)

• Contamination Control Plan (PLN-5509)

• Backfill and Restoration Plan (PLN-5510)

• Stormwater Pollution Prevention Plan (PLN-5511)

• Chronic Beryllium Disease Prevention Program (PLN-5512)

• Radiation Protection Plan (PLN-5513)

• U.S. Environmental Protection Agency Tier 1 Qualified Facility Spill Prevention, Control, and Countermeasures (SPCC) Plan (PLN-5514)

5.2 MOBILIZATION AND INFRASTRUCTURE CONSTRUCTION

Major infrastructure installed at the site is listed below and shown on Figure 2.

• Support zone (SZ) o USACE trailer, 60 ft by 24 ft, furnished (leased) o Break trailer, 66 ft by 24 ft, furnished (leased) o Three contractor’s office trailers, 60 ft by 24 ft, furnished (leased) o Employee parking lot o On-site laboratory; that consists of four trailers, includes laboratory equipment

(contractor owned) o Truck scale (contractor owned) o Scale house (Conex box) (government owned) o Access roads o Wastewater treatment plant (WWTP) (government owned) o 265,000 gallon water storage tank (government owned) o Five 21,000 gallon water storage tanks (government owned) o 18,000 gallon weir tank (government owned) o Potable water treatment system (government owned) o Meteorological station (contractor owned) o Roll-off boxes (leased) o Roll-off box staging area

Remediation of Soils Operable Unit Contract W912P420R0004

15 June 2020 o Project sign o Utilities and services (electric, Internet, water [from on-site well], portable restrooms, and trash removal)

• Contaminant reduction zone (CRZ) o Access control/worker showers (government owned) o Industrial hygiene/radiological equipment storage (government owned) o Optical fluorescence system (government owned)

• Exclusion zone (EZ) - Soil processing area o Decontamination pad (government owned) o Two concrete pads for soil staging and load-out (government owned) o Soil stockpile area, gravel base with liner and drainage system (government owned) o Enclosed (Rubb) structure and concrete base (government owned) o Worker heating/cooling enclosure (government owned) o Portable air monitoring stations (contractor owned)

• EZ - Excavation area o Access roads o 4-inch self-prime trash pump (government owned) o Grizzly bar screener (government owned) o Portable air monitoring stations (contractor owned)

• EZ – Site-wide o Security cameras (government owned) o Global positioning system (GPS) apparatus for construction equipment

(government owned) o Perimeter air monitoring stations (contractor owned) o Erosion and sedimentation control features (government owned)

5.3 REMEDIAL ACTION

Excavation of contaminated soil began in April 2018 in the southern portion of the site (Lagoons A, B, and C). Excavated soils were processed using an automated soil sorting system that utilized radiological scanning technology. The soil sorting system was taken off-line in November 2018 when soil processing was converted to a manual operation.

5.3.1 Soil Excavation and Transportation

Remediation of contaminated soil uses a direct load-out and disposal approach. Areas requiring remediation are characterized beforehand. Excavated soils are transferred to a staging area for conditioning, packaging, and shipment to an off-site disposal facility. Excavation is performed using global positioning system (GPS) guided equipment.

Sampling and analysis is performed to characterize the waste and determine:

• U.S. Department of Transportation (DOT) shipping class and proper shipping name.

• Whether the material meets the disposal facility’s waste acceptance criteria (WAC).

Soil samples are taken at a frequency of approximately one grab sample for each 10 cubic yards (CY) and composites are made for each 400 CY of soil.

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At the soil processing area excavated material is segregated into debris and soil stockpiles. If necessary, the soils are conditioned using a calcium oxide/pozzolan product that promotes drying and improves strength1. The waste soil/fill is then packaged using DOT IP-1 rated flexible bulk inner packaging and outer bulk roll-off containers (25 CY capacity). Packaged waste is transported over the highway to a disposal facility. The IP-1 packages prevent beryllium exposure to workers at the disposal facility.

The roll-off boxes have been loaded with approximately 16.8 tons of soil. A sustainable shipping rate of 1,080 tons per week has been achieved. Approximately 2,200 soil samples have been collected and analyzed2.

5.3.2 Water Treatment

Potentially contaminated water from contaminated areas, the excavations, soil processing pads, and the decontamination pad is processed through an on-site WWTP prior to off-site…