Harshaw RA RFP Section C_Draft_2022-11-15.pdf

Section C Technical Scope

Remediation of Operable Units 1 and 2

Former Harshaw Chemical Company Site Cleveland, Ohio

NOVEMBER 2022

FORMERLY UTILIZED SITES REMEDIAL ACTION PROGRAM

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Former Harshaw Chemical Company Site Remediation of Operable Units 1 & 2

Contract W912P422R0015 Section C Technical Scope iii November 2022

TABLE OF CONTENTS

1.0 GENERAL

1.1 Contract Award

1.2 Scope of Work

2.0 STATUTORY AUTHORITY, REGULATORY COMPLIANCE, ADMINISTRATIVE

RECORD AND STAKEHOLDERS

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 Operations and Environmental Activities

3.2.1 Previous Operations

3.2.2 Previous Environmental Activities

4.0 SITE CONDITIONS AND REMEDY COMPONENTS

4.1 Topography and Drainage

4.2 Geology and Hydrogeology

4.2.1 Geology

4.2.2 Hydrogeology

4.3 Remedy Components

4.3.1 Constituents of Concern

4.3.2 Remedial Action Objective

4.3.3 Selected Remedy

4.3.4 Cleanup Goals

4.3.5 Contaminated Areas/Media

5.0 REMEDIATION ACTIVITIES

5.1 Task 1 - Mobilization

5.2 Task 2 – Soil Remediation

5.3 Task 3 – Transportation and Disposal

5.4 Task 4 - Demobilization

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6.0 REMEDIATION REQUIREMENTS

6.1 Task 1 - Mobilization

6.1.1 Mobilization and Preparatory Work (331XX01)

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

6.1.3 General Requirements (331XX22)

6.2 Task 2 – Soil Remediation

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

6.2.2 Site Work (331XX03)

6.2.3 Surface Water Collection and Control (331XX05)

6.2.4 Solids Collection and Containment (331XX08)

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

6.2.6 Disposal (331XX19)

6.2.7 Site Restoration (331XX20)

6.2.8 General Requirements (331XX22)

6.3 Task 3 – Transportation and Disposal

6.3.1 Disposal (331XX19)

6.4 Task 4 – Demobilization

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

6.4.2 Disposal (Commercial) (331XX19)

6.4.3 Site Restoration (331XX20)

6.4.4 Demobilization (331XX21)

6.4.5 General Requirements (331XX22)

7.0 SAFETY REQUIREMENTS

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)

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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

TABLES

Table 1: Previous Manufacturing Operations

Table 2: Previous Activities and Documents Associated with Radiological Processes and Contamination

Table 3: Previous Activities and Documents Associated with Non-radiological Processes and Contamination

Table 4: Maximum and Background COC Concentrations in Soil

Table 5: Site Cleanup Goals

Table 6: Estimated Volumes of FUSRAP-contaminated Soils and Debris

Table 7: USACE Accepted FUSRAP Waste Disposal Facilities

APPENDICES

Appendix A Figures Figure 1 Site Location Figure 2 Site Features for OU-1 Figure 3 Site Features for OU-2

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Figure 4 Monitoring Well Locations and the Spatial & Vertical In-situ Extent of FUSRAP Contaminated Soil for OU-1

Figure 5 Monitoring Well Locations and the Spatial & Vertical In-situ Extent of FUSRAP Contaminated Soil for OU-2

Figure 6 USACE Access for FUSRAP Remediation Areas in OU1

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

ATTACHMENTS

Attachment 1 Supporting Information

1.1 Contaminated Soil Volume Estimate Summary

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1.2 Historical Information

Attachment 2 USACE Standard Operating Procedures and Forms

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 Eng. Form 4025-R Eng. Form 4288-R APP/SSHP Checklist NWW Form 385-1 (Rev. April 2008) Activity Hazardous Analysis Template USACE Buffalo District Monthly Manhour Exposure Report Eng. Form 3394 Accident Investigation Report DA Form 5383-R Hot Work Permit

Attachment 3 ERPIMS Data Format Dictionary Attachment 4 Submittal Summary Attachment 5 HTRW Remedial Action Work Breakdown Structure and Data Dictionary Attachment 6 Decision Framework for Incorporation of Green and Sustainable Practices into Environmental Remediation Projects Attachment 7 Progress Payment Checklist Attachment 8 Bid Schedule

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ACRONYMS AND ABBREVIATIONS

AACE AACE International AASHTO American Association of State Highway and Transportation Officials AEC (U.S.) Atomic Energy Commission AECOM AECOM Environment AEIC Association of Edison Illuminating Companies AF actual finish AHA activity hazard analysis AHRI Air Conditioning, Heating and Refrigeration Institute ALARA as low as reasonably achievable ANSI American National Standards Institute APP accident prevention plan ARAR applicable or relevant and appropriate requirement AS actual start ASME American Society of Mechanical Engineers ASSP American Society of Safety Professionals ASTM ASTM International AWP aerial work platform AWPA American Wood Protection Association AWWA American Water Works Association

BIDI bid item BCY bank cubic yard(s) bgs below ground surface BMP best management practice Bq/cm2 becquerels per square centimeter Bq/g becquerels per gram

CAS chemical abstract system CERCLA Comprehensive Environmental Response, Compensation, and Liability Act cfm cubic feet per minute CFR Code of Federal Regulations CHP Certified Health Physicist CIH Certified Industrial Hygienist CLIN contract line item number cm/sec centimeters per second COCs constituents of concern COR Contracting Officer’s Representative

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CP competent person CPR cardiopulmonary resuscitation CPFF cost plus fixed fee CPM critical path method CQC Contractor quality control CQCSM Construction Quality Control System Manager CQM construction quality management CR conformance review CRZ contamination reduction zone CSP Certified Safety Professional CY cubic yard(s)

DA Designer of Record approval DCAA Defense Contract Audit Agency DCGL derived concentration guideline level DCGLEMC derived concentration guideline level (elevated measurement comparison) DFARS Defense Federal Acquisition Regulation Supplement DFOW definable feature of work DLA (U.S.) Defense Logistics Agency DO dissolved oxygen DOD (U.S.) Department of Defense DOE (U.S.) Department of Energy DOR Designer of Record DOT (U.S.) Department of Transportation dpm/100cm2 disintegrations per minute per 100 square centimeters 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 ERPIMS Environmental Restoration Program Information Management System

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EZ exclusion zone

FDGC Federal Geographic Data Committee FFP firm-fixed price FHWA Federal Highway Administration FIO for information only FOUO For Official Use Only FOW feature of work FP fall protection FSS final status survey

ft. foot (feet) ft2 square feet ft/day feet per day FUSRAP Formerly Utilized Sites Remedial Action Program g gram GFE Government furnished equipment GFP Government furnished property GIS geographic information system gpm gallons per minute GPS global positioning system GSR Green and Sustainable Remediation GWS gamma walkover survey

HECP hazardous energy control program HLL horizontal lifeline HP health physics HTRW hazardous, toxic and radioactive waste

IA Investigative Area IATA International Air Transportation Association IEEE Institute of Electrical and Electronics Engineers IH industrial hygiene IPS initial project schedule ISO International Organization for Standardization IT Innovative Technologies ITR independent technical review

LACW low activity comingled waste

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LARW low activity radioactive waste lbs pounds LCS laboratory control sample LEL lower explosive limit LHE load handling equipment LLRW low-level radioactive waste

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 MHE material handling equipment mph miles per hour mrem/yr. millirems per year MS matrix spike MSD matrix spike duplicate MUTCD Manual on Uniform Traffic Control Devices MW mixed waste

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 NCRP National Council on Radiation Protection Measurements NEA negative exposure assessment NELAC National Environmental Laboratory Accreditation Conference NEMA National Electrical Manufacturer’s Association NEORSD Northeast Ohio Regional Sewer Water District 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 NQA nuclear quality assurance NRC (U.S.) Nuclear Regulatory Commission NTP notice to proceed NTU nephelometric turbidity unit NVLAP National Voluntary Laboratory Accreditation Program

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OACSIM Office of the Assistant Secretary for Installation Management 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 Ohio EPA Ohio Environmental Protection Agency O&M operation and maintenance ORP oxidation-reduction potential OSH Occupational Safety and Health OSHA Occupational Safety and Health Administration OU operable unit

PAH polycyclic aromatic hydrocarbon PBZ personal breathing zone PCBs polychlorinated biphenyls pCi/g picocuries per gram pdf portable document format PDM precedence diagram method PEL permissible exposure limit PMP Project Management Professional PPE personal protective equipment ppm parts per million psi pounds per square inch PVC polyvinyl chloride

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

Ra radium Ra-226 radium 226 RCRA Resource Conservation and Recovery Act

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REMG Resident Engineer Management Guide RESP responsibility RESRAD RESidual RADiation RFI request for information RFP request for proposal RI remedial investigation RMS Resident Management System RMS CM Resident Management System Contractor Mode RMS GM Resident Management System Government Mode ROC Regional Off-site Coordinator ROD record of decision RPD relative percent difference RTS Return To Service RSO Radiation Safety Officer RSSO Radiation Safety Staff Officer RSPA Research and Special Projects Administration RSST Radiation Safety Support Team

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 SEG similar exposure groups SF start-to-finish 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 SVC schedule variance control

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SVOCs semi-volatile organic compounds SWMU solid waste management unit SWPPP storm water pollution prevention plan SZ support zone

TEDE total effective dose equivalent Th thorium Th-230 thorium 230 Th-232 thorium 232 TIA Telecommunications Industry Association TSDF treatment, storage, and disposal facility TSP total suspended particulate TWA time weighted average

U uranium U-238 uranium 238 UFGS Unified Facilities Guide Specification UFP Uniform Federal Policy 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

VOCs volatile organic compounds VVL valid value list

WAC waste acceptance criteria WBS work breakdown structure WMP water management plan WRS Wilcoxon Rank Sum

yr. year µCi/mL microcuries per milliliter µg/m3 micrograms per cubic meter

Contract W912P422R0015 Section C Technical Scope

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1.0 GENERAL

1.1 CONTRACT AWARD

The United States Army Corps of Engineers (USACE) intends to award a three-year Type C contract to remediate the Former Harshaw Chemical Company Site (site) in Cleveland, Cuyahoga County, Ohio. The site is included in the government’s Formerly Utilized Sites Remedial Action Program (FUSRAP). The contract will be procured as a set aside for small business.

1.2 SCOPE OF WORK

This technical scope identifies activities needed to remediate FUSRAP-contaminated soils at the site in accordance with the Record of Decision for Operable Unit (OU)-1 and OU-2 (USACE 2021). Contamination encountered at the site is summarized in Section 4.

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

• Preparation of site-specific work plans and other required pre-construction submittals.

• Mobilizing to the site and setting up construction equipment and facilities.

• Sampling and laboratory analysis.

• Collecting, treating and discharging water from the exclusion zone and contaminant reduction zone.

• Monitoring industrial hygiene/health and safety of site workers.

• Implementing contamination control measures and monitoring their effectiveness.

• Excavating, packaging, transporting and disposing FUSRAP-contaminated soil off-site.

• Packaging, transporting and disposing universal, hazardous, industrial and “household” waste generated from remediation activities (i.e., vehicle fluids, office trash, etc.) off-site.

• Performing confirmation sampling and final status surveys of remediated areas.

• Providing engineering, surveying and quality control inspections/monitoring.

• Developing, operating and maintaining an electronic file sharing system and database that is compatible with the USACE Information Technology network.

• Assisting USACE with preparation for and participation at public meetings.

• Restoring excavated areas, material handling areas and support zones.

The contractor will consult with and provide technical support services to USACE throughout the remedial action. Expertise is required in the following areas:

• Environmental remediation

• Health physics monitoring and worker safety

• Installation, operation and maintenance of air monitoring systems

• Environmental laboratory operations

• Water treatment system operation and maintenance

• Database programming and maintenance

• Waste classification, manifesting and shipping

• Hazardous material surveys

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Work elements described in this technical scope 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 5.

2.0 STATUTORY AUTHORITY, REGULATORY COMPLIANCE,

ADMINISTRATIVE RECORD AND STAKEHOLDERS

2.1 STATUTORY AUTHORITY

USACE is the lead federal agency for the remedial action and has overall responsibility for project execution 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 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 FUSRAP activities at the site is available at the following locations.

U.S. Army Corps of Engineers1 1776 Niagara Street Buffalo, New York 14207 1-800-833-6390 (Option 4) City of Cleveland Public Library 325 Superior Avenue Cleveland, Ohio 44114

(216) 623-2800 Cuyahoga County Library, Brooklyn Branch 4480 Ridge Road Brooklyn, Ohio 44144

Reports, fact sheets, and public presentation documents are also available at https://www.lrb.usace.army.mil/Missions/HTRW/FUSRAP/Harshaw-Site/.

2.4 STAKEHOLDERS

Principal stakeholders are listed below.

• BASF Corporation

• BGD Company

• CSX Railroad

1 By appointment only.

https://www.lrb.usace.army.mil/Missions/HTRW/FUSRAP/Harshaw-Site/

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• East Ohio Gas Company

• E&S Property Managers, LLC

• Harshaw Chemical Company

• The Stratonovich Group, LLC

• Pavlish Real Estate Holding

• City of Cleveland o Justin Bibb, Mayor o Rebecca Maurer, City Council Ward 12 o Rachid Zoghaib, Deputy Commissioner Department of Public Works o Freddy L. Collier, Jr., Director, City Planning Commission

• Northeast Ohio Regional Sewer Water District (NEORSD)

• Ohio Environmental Protection Agency (Ohio EPA)

• Ohio Department of Health (ODH)

• State of Ohio o Mike DeWine, Governor o State House of Representatives 11th District (vacant January 2022) o Sandra R. Williams, State Senate 21st District

• Federal Government o Shontel Brown, U.S. House of Representatives 11th District o Sherrod Brown, U.S. Senate o Robert Portman, U.S. Senate

• U.S. Department of Energy (DOE)

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

• Canalway Partners

• Cuyahoga River Restoration/AOC

• Big Creek Connect

3.0 SITE BACKGROUND

3.1 SITE LOCATION AND DESCRIPTION

The site is located at 1000 Harvard Avenue in Cleveland, Ohio, three miles south of downtown Cleveland (Figure 1). It is a 55-acre property that includes several developed and undeveloped land parcels near the intersection of Harvard Avenue and Jennings Road. Developed parcels include former production areas with foundations, parking areas associated with demolished buildings, and redeveloped, privately-owned commercial properties. Industries and commercial businesses surround the site. Neighboring industries include Arcelor Mittal Steel, Aluminum Company of America (Alcoa Corporation), Chemical Solvents, Inc., and CSP Fabricating. There are also a few private residences near the site.

The site is separated into two operable units (OUs) and an investigative area (IA) for environmental remediation associated with FUSRAP. OU-1 is located north of Big Creek and west of the Cuyahoga River (Figure 2). Former buildings in this area have been removed. The southern section contains a property developed for truck and equipment servicing. The remainder is undeveloped industrial properties, open fields and wooded areas. OU-2 is south of

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Big Creek and west of the Cuyahoga River (Figure 3). It mainly consists of undeveloped industrial properties and open fields. A municipality-owned property and a trucking company are in the northwest section. The southern section contains a closed solid waste landfill.

IA-06 is an undeveloped parcel located east of the Cuyahoga River and north of Harvard Avenue. Remediation of this area is not required.

3.2 PREVIOUS OPERATIONS AND ENVIRONMENTAL ACTIVITIES

3.2.1 Previous Operations

The Harshaw, Fuller and Goodwin Company acquired the property in 1905 from the Canadian Copper Company. It operated the property until 1983 when its then parent, Gulf Oil and Kaiser Clay and Chemical, formed the Harshaw/Filtrol partnership. Chevron Chemical Company became a partner in 1985. Chevron sold its share of the Harshaw/Filtrol partnership, except Building G-1, to Kaiser in 1987. In 1998, the Englehard Corporation purchased the entire site, except for Building G-1, which remained owned and operated by the Chevron/Kaiser Partnership. In the early 1990s, BASF purchased the site, except for Building G-1, which remained owned and operated by the Chevron/Kaiser Partnership.

Table 1 provides a summary of manufacturing operations at the site during this period (AECOM 2010).

Table 1: Previous Manufacturing Operations

Activity Date Production of nickel salts, cobalt oxide, and hydrofluoric acid 1918 Production of liquid chemical brighteners, hydrofluoric acid production capacity upgraded 1930s

Miscellaneous fluorides plant operations 1930 - 1950 Nickel salts manufacturing process expanded 1940s Processing of uranium compounds for the Manhattan Engineering District (MED) 1940s

Fluoride production capability increased Late 1960s Wastewater treatment systems added Late 1970s Nickel carbonate production added Late 1970s – early 1980s Hydrofluoric acid manufacturing terminated 1985 Production of nickel catalysts, catalyst intermediates (i.e., nickel carbonate), extruded catalysts, miscellaneous fluorides and fluoroborates, metal finishing products, color plate products, and electrolus products

Late 1980s – 1990s

Between 1944 and 1953, the MED and Atomic Energy Commission (AEC) used the site to process uranium. The primary production process involved refining of uranium oxide feed material to produce uranium tetrafluoride (green salt), uranium hexafluoride, and uranium trioxide. The uranium processing operations were conducted in Building G-1.

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3.2.2 Previous Environmental Activities

Environmental activities associated with radiological processes and contamination at the site are summarized in Table 2.

Table 2: Previous Activities and Documents Associated with Radiological Processes and Contamination

Activity Date Processing of uranium compounds for the MED 1940s Uranium processing equipment decontaminated by Harshaw under AEC guidance. 1960

Radiological surveys performed by Argonne National Laboratories to determine the extent of impacts at the site. 1974 – 1979

Radiological surveys of buildings, soil, and groundwater conducted by ADA Consultants and B. Koh Associates for Engelhard Corporation. 1989 - 1998

Radiologically-contaminated structures were decontaminated, resurveyed, and released for unrestricted use by the Nuclear Regulatory Commission (NRC).

Eleven structures were demolished and Building G-1 remained under the ownership of Chevron (or its affiliate).

1997 - 1998

The site was designated for inclusion under FUSRAP. June 3, 1999 Preliminary assessment completed April 2001 Remedial investigation (RI) completed December 2009 Annual groundwater monitoring performed by USACE 2009 - 2017 Proposed plan for IA-06 issued April 2010 No-action record of decision (ROD) for IA-06 issued March 2011 Feasibility study for OU-1 and OU-2 completed September 2012

Building G-1 deconstructed December 2014 – May 2015

Building G-1 deconstruction report issued May 2016 Feasibility study addendum for OU-1 and OU-2 completed September 2018 Proposed plan issued March 2019 ROD for OU-1 and OU-2 issued September 2021

In March 2010, the USEPA issued an administrative order to BASF for RCRA correction action at the site.2 USEPA determined that corrective action was needed to protect human health and the environment due to releases of hazardous wastes and materials at the site (USEPA 2014).

Environmental activities related to non-FUSRAP contamination (i.e., the RCRA administrative order) are summarized in Table 3.

2 RCRA is the Resource Conservation Recovery Act (40 CFR Part 280).

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Table 3: Previous Activities and Documents Associated with Non-radiological Processes and Contamination

Activity Date Initial RCRA Part A Notification of Hazardous Waste Activity submitted August 1980 Several RCRA inspections were performed and violations were identified 1980 – 1988 Hazardous Waste Facility Installation and Operation Permit received from the State of Ohio December 1981

Harshaw/Filtrol partnership received interim status from the USEPA August 1982 NEORSD sampled a sanitary sewer manhole downstream from the site and detected nickel above the wastewater limit. May 1987

RCRA Part B application submitted November 1988 RCRA Part B application withdrawn October 1989 Closure plan for hazardous waste management units submitted October 1989 Closure plan accepted by Ohio EPA August 1990 Hazardous waste management units closed and approved by Ohio EPA February 1992 Groundwater extraction and treatment system installed to control the infiltration of nickel-contaminated groundwater to an interceptor beltline sewer.

June 1994

RCRA 3008(h) Administrative Order issued to BASF Catalysts for correction action at the site to remediate heavy metals in soil and groundwater.

March 2010

Draft Description of Current Conditions report submitted in response to the RCRA Administrative Order. June 2010

Storm water outfalls closed September - October

City of Cleveland joint order issued to BASF Corporation to abate illicit discharges from the property. October 2014

USEPA administrative order issued to BASF Corporation to stop discharging polluted waters from its property to the Cuyahoga River without a permit.

October 2014

Five site buildings removed 2015 Storm Water Outfall Investigation and Closure Report issued March 2015

BASF operates a pump and treat system to remediate nickel contamination pursuant to an order from the state of Ohio. The groundwater extraction system consists of eight recovery wells. The average total flow rate from these wells is approximately 2.7 gallons per minute. Extracted groundwater is pumped to an on-site treatment system that uses chemical precipitation and flocculation. Resulting solids are processed through a filter press and sent off-site. Treated water is discharged to a sanitary sewer under a permit issued by NEORSD (AECOM 2010).

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4.0 SITE CONDITIONS AND REMEDY COMPONENTS

4.1 TOPOGRAPHY AND DRAINAGE

The site is located near the confluence of the Cuyahoga River and Big Creek. Low-lying areas along the river and creek lie within a Q3 Federal Emergency Management Agency Flood Hazard Area. The northern portion of the site is characterized by low relief and a gentle eastward slope.

A relatively steep bank is present along the west side of the river. The land surface in the middle of the site is approximately 10 to 15 ft higher than the river and creek channel bottoms. The land surface in the northern portion of the site has been modified to permit the construction of buildings, paved surfaces and drainage. All developed parcels within the site have been filled to raise the land surface elevation and limit the potential for flooding.

In 2014 and 2015, the property owner (BASF Corporation) removed multiple segments of a stormwater system. Surface water ponding now occurs in various areas of the site. The southern portion of the site is mainly undeveloped. Surface water runoff from this area is controlled by drainage ditches and culverts associated with adjacent railroad tracks.

4.2 GEOLOGY AND HYDROGEOLOGY

4.2.1 Geology

The site is underlain by up to 22 feet (ft.) of unconsolidated material (i.e., overburden) over shale bedrock. The bedrock is relatively shallow beneath the central and northern part of the site and becomes deeper to the north, east, west, and south where the thickness of the unconsolidated material increases. The overburden consists of anthropogenic fill and native alluvial sediments.

The alluvium contains fluvial (coarse-grained) and floodplain (fine-grained) sediments (USACE 2009).

4.2.2 Hydrogeology

Groundwater primarily occurs within saturated fill and alluvium. The underlying shale bedrock contains a thin fractured zone (less than 5 ft. thick) that has been observed to be dry in the vicinity of former Building G-1 and a boiler house (i.e., where bedrock is shallow) and saturated away from this area where bedrock deepens. The shale bedrock is not a significant groundwater-bearing zone. Similarities observed between groundwater levels within the overburden and fractured bedrock suggest these zones are hydraulically connected.

Potentiometric maps indicate that groundwater flow in the overburden is generally from west to east across the site. It appears to be influenced by the bedrock elevations and changes in surface water levels in the Cuyahoga River and Big Creek. A belt line sewer trench in the western and northern portions of OU-1 may also act as a preferential groundwater pathway in this area.

Slug tests conducted on 23 monitoring wells during the RI resulted in hydraulic conductivity values that varied by several orders of magnitude due to heterogeneity of the fill and alluvium.

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4.3 REMEDY COMPONENTS

4.3.1 Constituents of Concern

FUSRAP constituents of concern (COCs) for OU-1 and OU-2 soils include radium (Ra)-226, thorium (Th)-230, Th-232, and total uranium (U). Maximum and background levels identified in USACE investigations are listed in Table 4.

Table 4: Maximum and Background COC Concentrations in Soila

COC

OU-1 OU-2 Mean Background

Concentrationb Maximum Detected Maximum Detected

Ra-226 19.23 7.98 0.941 Th-230 632 84.5 0.878 Th-232 329 74.8 0.981 U-238c 2,710 1,680 1.27

Notes:

a All values in units of picocuries per gram (pCi/g).

b Mean background values were calculated using natural soil samples from 0 to 13 ft below ground surface.

c U-238 was used as a surrogate for total U.

4.3.2 Remedial Action Objective

The remedial action objective developed for soil in OU-1 and OU-2 is to prevent exposure to impacted soil containing concentrations of COCs to ensure the critical receptor does not receive a total effective dose equivalent (TEDE) exceeding 25 millirems per year (mrem/yr.) above background. The critical receptor at OU-1 is a construction worker. The critical receptor at OU- 2 is a resident adult.

4.3.3 Selected Remedy

The ROD-selected remedy is complete removal of FUSRAP-contaminated soil from OU-1 and OU-2 and off-site disposal at a properly permitted or licensed facility. FUSRAP-contaminated soil from these areas would be characterized as low activity radioactive waste (LARW) or low activity comingled waste (LACW). LARW is regulated or non-regulated radioactive waste that does not require treatment prior to disposal in accordance with 10 CFR 61 or 10 CFR 40, Appendix A. LACW is waste that contains both LARW and hazardous waste that may require treatment prior to land disposal in accordance with RCRA land disposal restrictions.

The OU-1 remedy includes the following additional requirements:

• All private utilities encountered during the remedial action will be decommissioned and sealed to prevent the migration of residual uranium in groundwater.

• Any public utilities encountered during the remedial action will be left in place and backfilled with amended material to minimize the migration of groundwater and uranium transport along the utility trenching.

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9 November 2022

4.3.4 Cleanup Goals

Cleanup goals for contaminated soils are derived concentration guideline levels (DCGLs) that are protective of human health and the environment and comply with applicable or relevant and appropriate requirements (ARARS).3 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). For the site, this means that the critical receptor does not receive a dose of more than 25 mrem/yr TEDE above background from FUSRAP-related contamination. Table 5 identifies the cleanup goals.

Table 5: Site Cleanup Goals a,b

COC OU-1

(pCi/g)

OU-2

(pCi/g)

Mean Background (pCi/g)

Ra-226c 9.1 3.6 0.941 Th-230 35 16 0.878 Th-232d 6 3.6 0.981 U-238e 190 150 1.27

Notes:

a All values represent minimum RESidual RADiation (RESRAD) Computer Code calculated DCGLs at years 0, 185, or 1,000 (i.e., year of peak dose per nuclide group).

b Groundwater was not considered a drinking water source the during development of the cleanup goals.

They are based on a dose of 25 mrem/yr. TEDE for each radionuclide.

c DCGL includes Pb-210 contribution to the dose at time 0.

d DCGL includes Ra-228 and Th-228 contribution to the does at time 0.

e U-238 is not a COC, although the DCGL for U-238 will be used as a surrogate for total U during the remedial action.

4.3.5 Contaminated Areas/Media

The nature and extent of soil and groundwater contamination at the site is summarized below.

Information discussed in this section is supported by tables and figures in Attachment 1.2.

Complete information associated with FUSRAP activities at the site is available in the administrative record file and at https://www.lrb.usace.army.mil/Missions/HTRW/FUSRAP/Harshaw-Site/. Some BASF RCRA documents are available at https://www.epa.gov/hwcorrectiveactionsites/hazardous-waste-cleanup-basf-corporation-cleveland-ohio.

4.3.5.1 FUSRAP Contamination

4.3.5.1.1 Soil

The extent of FUSRAP-contaminated soil is illustrated on Figures 4 and 5. It is irregularly distributed in OU-1 and OU-2. Most areas have contamination in surface soil (i.e., 0 to 2 ft.

below ground surface [bgs]) and shallow subsurface soil (i.e., 2 to 13 ft. bgs). Contaminated soil

3 DCGLs are based on requirements in Chapter 10, Code of Federal Regulations, Part 20 (§10 CFR 20), Subpart E – Radionuclides.

https://www.lrb.usace.army.mil/Missions/HTRW/FUSRAP/Harshaw-Site/ https://www.epa.gov/hwcorrectiveactionsites/hazardous-waste-cleanup-basf-corporation-cleveland-ohio https://www.epa.gov/hwcorrectiveactionsites/hazardous-waste-cleanup-basf-corporation-cleveland-ohio

Contract W912P422R0015 Section C Technical Scope

10 November 2022 along the west bank of the Cuyahoga River is present to 16.8 ft. bgs. Fill material (i.e., brick, wood, concrete) was observed in many areas of deeper contamination.

Pavement and foundations will need to be removed in some locations to access the contamination. Table 6 provides estimated volumes of FUSRAP-contaminated soil and debris in OU-1 and OU-2.

Table 6: Estimated Volumes of FUSRAP-contaminated Soils and Debris

Item

OU-1

(BCY)

OU-2

(BCY)

FUSRAP-contaminated soil 10,195 808 Debris (pavement and foundations) to be excavated 1,654 269

Notes:

BCY is bank cubic yard(s)

4.3.5.1.2 Groundwater

A uranium-contaminated groundwater plume is present in OU-1, beneath and near former Building G-1. Depth to groundwater in this area varies seasonally. Operation of the extraction well system that removes nickel-contaminated groundwater may influence groundwater flow in the western section of OU-1.

FUSRAP-contaminated groundwater has not been identified beneath OU-2.

4.3.5.2 RCRA Contamination

4.3.5.2.1 Solid Waste Management Units (SWMUs)

A Description of Current Conditions report identified 37 SWMUs and eight areas of concern at the site from historical documents (AECOM 2010). Site inspections conducted in 2007 and 2010 determined that most were no longer present and/or no impacts were observed. A SWMU (Landfill A) is situated along the bank of the Cuyahoga River in the northeast section of the site.

It is approximately 550 ft long by 60 ft wide and was used for calcium sulfate waste produced from a former hydrogen fluoride plant. The landfill is unlined and its northernmost section was overlain by a scrap yard.

4.3.5.2.2 Soil

Laboratory analyses for non-radiological constituents have historically been limited to inorganics associated with former site processes and waste materials. Elevated constituents in soil include nickel, chloride and sulfate, which were associated with nickel chloride/nickel sulfate production. Of the constituents identified in soil, nickel is the most prevalent. The distribution of nickel in surface and shallow subsurface soil in shown on figures in Attachment 1.2.

The USACE RI analyzed soil samples for volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs) and inorganic constituents. Polycyclic aromatic hydrocarbons (PAHs) were detected along with low levels of other SVOCs and certain VOCs.

Contract W912P422R0015 Section C Technical Scope

11 November 2022

4.3.5.2.3 Groundwater

Previous groundwater investigations analyzed for constituents used in facility processes, specifically nickel, chloride and sulfate. Elevated concentrations were identified in samples collected beneath or downgradient of former nickel sulfate and nickel chloride manufacturing areas. Groundwater results for dissolved nickel are summarized in Attachment 1.2.

5.0 REMEDIATION ACTIVITIES

Remediation activities required by the contract are summarized below.

1. Mobilization

2. Soil Remediation (FUSRAP-contaminated soil and debris)

a. OU-1

b. OU-2

3. Transportation and Disposal (FUSRAP-contaminated soil and debris)

a. OU-1

b. OU-2

4. Demobilization Remediation tasks are identified below. The project will use the USACE HTRW WBS (Attachment 5). Work requirements are described in Section 6.0.

5.1 TASK 1 - MOBILIZATION

• 331XX01 Mobilization and Preparatory Work o 331XX0101 – Mobilization of Construction Equipment and Facilities o 331XX0102 – Mobilization of Personnel o 331XX0103 – Submittals/Work Plans o 331XX0104 – Setup/Construct Temporary Facilities o 331XX0105 – Construct Temporary Utilities

• 331XX02 Monitoring, Sampling, Testing and Analysis o 331XX0201 – Meteorological Monitoring o 331XX0202 – Radiation Monitoring o 331XX0203 – Air Monitoring and Sampling o 331XX0204 – Monitoring Wells o 331XX0205 – Sampling Surface Water/Groundwater/Liquid Waste o 331XX0206 – Sampling Soil and Sediment o 331XX0208 – Sampling Radioactive Contaminated Media o 331XX0209 – Laboratory Chemical Analysis o 331XX0210 – Radioactive Waste Analysis o 331XX0211 – Geotechnical Testing o 331XX0213 – On-site Laboratory Facilities (Optional) o 331XX0214 – Off-site Laboratory Facilities

• 331XX22 General Requirements o 331XX2201 – Supervision and Management o 331XX2204 – Engineering, Surveying and Quality Control o 331XX2206 – First Aid, Fire Protection, Traffic Control and Security

Contract W912P422R0015 Section C Technical Scope

12 November 2022 o 331XX2207 – Health and Safety o 331XX2208 – Temporary Construction Facilities (Ownership) o 331XX2209 – Temporary Construction Facilities (Operation) o 331XX2210 – Project Utilities

5.2 TASK 2 – SOIL REMEDIATION

• 331XX02 Monitoring, Sampling, Testing and Analysis o 331XX0201 – Meteorological Monitoring o 331XX0202 – Radiation Monitoring o 331XX0203 – Air Monitoring and Sampling o 331XX0204 – Monitoring Wells o 331XX0205 – Sampling Surface Water/Groundwater/Liquid Waste o 331XX0206 – Sampling Soil and Sediment o 331XX0208 – Sampling Radioactive Contaminated Media o 331XX0209 – Laboratory Chemical Analysis o 331XX0210 – Radioactive Waste Analysis o 331XX0211 – Geotechnical Testing o 331XX0213 – On-site Laboratory Facilities (Optional) o 331XX0214 – Off-site Laboratory Facilities

• 331XX03 Site Work o 331XX0302 – Clearing and Grubbing o 331XX0304 – Roads/Parking/Curbs/Walks o 331XX0305 – Fencing

• 331XX05 Surface Water Collection and Control o 331XX0507 – Sediment Barriers

• 331XX08 Solids Collection and Containment o 331XX0801 – Contaminated Soil Collection

• 331XX09 Liquids/Sediments/Sludges Collection and Containment o 331XX0907 – Lagoons/Basins/Tanks/Dikes/Pump System

• 331XX19 Disposal (Commercial) o 331XX1920 – Container Handling

• 331XX20 Site Restoration o 331XX2001 – Earthwork o 331XX2004 – Revegetation and Planting

• 331XX22 General Requirements o 331XX2201 – Supervision and Management o 331XX2204 – Engineering, Surveying and Quality Control o 331XX2206 – First Aid, Fire Protection, Traffic Control and Security o 331XX2207 – Health and Safety o 331XX2208 – Temporary Construction Facilities (Ownership) o 331XX2209 – Temporary Construction Facilities (Operation) o 331XX2210 – Project Utilities

Contract W912P422R0015 Section C Technical Scope

13 November 2022

5.3 TASK 3 – TRANSPORTATION AND DISPOSAL

• 331XX19 Disposal (Commercial) o 331XX1921 – Transportation to Storage/Disposal Facility o 331XX1922 – Disposal Fees and Taxes

5.4 TASK 4 - DEMOBILIZATION

• 331XX02 Monitoring, Sampling, Testing and Analysis o 331XX0201 – Meteorological Monitoring o 331XX0202 – Radiation Monitoring o 331XX0203 – Air Monitoring and Sampling o 331XX0204 – Monitoring Wells o 331XX0205 – Sampling Surface Water/Groundwater/Liquid Waste o 331XX0206 – Sampling Soil and Sediment o 331XX0208 – Sampling Radioactive Contaminated Media o 331XX0209 – Laboratory Chemical Analysis o 331XX0210 – Radioactive Waste Analysis o 331XX0211 – Geotechnical Testing o 331XX0213 – On-site Laboratory Facilities (Optional) o 331XX0214 – Off-site Laboratory Facilities

• 331XX19 Disposal (Commercial) o 331XX1920 – Container Handling o 331XX1921 – Transportation to Storage/Disposal Facility o 331XX1922 – Disposal Fees and Taxes

• 331XX20 Site Restoration

• 331XX21 Demobilization o 331XX2101 – Removal of Temporary Facilities o 331XX2102 – Removal of Temporary Utilities o 331XX2103 – Final Decontamination o 331XX2104 – Demobilization of Construction Equipment and Facilities o 331XX2105 – Demobilization of Personnel o 331XX2106 – Submittals

• 331XX22 General Requirements o 331XX2201 – Supervision and Management o 331XX2204 – Engineering, Surveying and Quality Control o 331XX2206 – First Aid, Fire Protection, Traffic Control and Security o 331XX2207 – Health and Safety o 331XX2208 – Temporary Construction Facilities (Ownership) o 331XX2209 – Temporary Construction Facilities (Operation) o 331XX2210 – Project Utilities

Contract W912P422R0015 Section C Technical Scope

14 November 2022

6.0 REMEDIATION REQUIREMENTS

Perform all work in accordance with this section.

Unified Facilities Guide Specifications (UFGS) modified for this contract are provided in Appendix B. Comply with all specifications and other Government requirements during execution of the work.

Provide a schedule that identifies the proposed sequence of work, activity durations and milestone dates.

A Bid Schedule is available in Attachment 8 for offeror’s proposed costs.

6.1 TASK 1 - MOBILIZATION

6.1.1 Mobilization and Preparatory Work (331XX01)

6.1.1.1 Mobilization of Construction Equipment and Facilities (331XX0101)

6.1.1.1.1 Work Requirements

Transport, assemble and set-up construction equipment and facilities prior to performing the remedial action. Work includes preparation of equipment for transport, equipment transportation and setup, drivers and equipment operators.4 Do not mobilize until all required work plans and other pre-mobilization submittals have been approved or accepted by USACE.

6.1.1.1.2 Applicable Guide Specifications

01 01 01 (REAL ESTATE), 01 35 26 (GOVERNMENTAL SAFETY REQUIREMENTS), 01 35

29.13 (HEALTH, SAFETY, & EMERGENCY RESPONSE PROCEDURES FOR

CONTAMINATED SITES), 01 50 00 (TEMPORARY CONSTRUCTION FACILITIES AND

CONTROLS), 01 45 00.00 10 (QUALITY CONTROL), 01 45 00.15 10 (RESIDENT

MANAGEMENT SYSTEM CONTRACTOR MODE [RMS CM]) and 01 57 23

(TEMPORARY STORM WATER POLLUTION CONTROL).

6.1.1.1.3 Proposal Requirements

Identify construction equipment, monitoring equipment, and supplies that will be mobilized to the site and used for the remedial action. Show mobilization on the schedule.

6.1.1.2 Mobilization of Personnel (331XX0102)

6.1.1.2.1 Work Requirements

Mobilize personnel who will be on-site full-time during the remedial action.

6.1.1.2.2 Applicable Guide Specifications and Technical Requirements 01 35 26 (GOVERNMENTAL SAFETY REQUIREMENTS) and 01 35 29.13 (HEALTH, SAFETY, & EMERGENCY RESPONSE PROCEDURES FOR CONTAMINATED SITES).

4 The contractor will be subject to the terms and conditions of all rights-of-entry between USACE and all property owners.

Contract W912P422R0015 Section C Technical Scope

15 November 2022

6.1.1.2.3 Proposal Requirements

Identify personnel who will be mobilized to the site and individuals who will be relocated.

6.1.1.3 Submittals/Work Plans (331XX0103)

6.1.1.3.1 Work Requirements

Provide submittals throughout the project duration (refer to Attachment 4).

Submit project schedules (preliminary, initial and periodic updates).

Prepare work plans to guide the remedial action.

• Site Operations Plan

• Accident Prevention Plan/Site Safety and Health Plan

• Contractor Quality Control Plan

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

(UFP-QAPP/SAP)

• Regulatory Compliance Plan

• Water Management Plan

• Waste Management, Transportation and Disposal Plan

• Final Status Survey Plan

• Contamination Control Plan

• Backfill and Restoration Plan

• Stormwater Pollution Prevention Plan

• Radiation Protection Plan

• USEPA Tier I Qualified Facility Spill Prevention, Control and Countermeasures (SPCC)

Plan

6.1.1.3.2 Applicable Guide Specifications

01 32 01.00 10 (PROJECT SCHEDULE), 01 33 00 (SUBMITTAL PROCEDURES), 01 35

13.43 10 (SPECIAL PROJECT PROCEDURES), 01 35 45 (CHEMICAL DATA QUALITY

CONTROL), 01 45 00.00 10 (QUALITY CONTROL), 01 45 00.15 10 (RESIDENT

MANAGEMENT SYSTEM CONTRACTOR MODE), 01 57 23 (TEMPORARY

STORMWATER POLLUTION CONTROL), 02 61 13 (EXCAVATION AND HANDLING OF

CONTAMINATED MATERIAL) and 02 81 00 (TRANSPORTATION AND DISPOSAL OF

HAZARDOUS MATERIALS).

6.1.1.3.3 Proposal Requirements

Identify pre-construction submittals and work plans that will be produced and show their completion milestones.

6.1.1.4 Setup/Construct Temporary Facilities (331XX0104)

6.1.1.4.1 Work Requirements

Procure, setup and construct temporary construction facilities and controls. Figure 6 shows OU- 1 areas that are available for the contractor’s use.

Contract W912P422R0015 Section C Technical Scope

16 November 2022

Minimum site infrastructure and temporary facilities required for the remedial action are listed below.

• Support zone (SZ) o USACE trailer, 12 ft by 60 ft, furnished o Break trailer, 12 ft by 60 ft, furnished o Contractor’s office trailer(s), furnished o Employee parking area o Project sign o Truck scale and scale house o Access roads o Wastewater treatment system and/or water storage tanks o Meteorological station o On-site laboratory (optional) o Utilities and services (electric, Internet, water, restrooms, and trash removal) o Clean equipment/supplies lay-down area and/or storage container(s)

• Contamination reduction zone (CRZ) o Access control/step-off pad/worker showers o Equipment, PPE and supplies storage o Construction water storage tanks and optional water treatment system o Staging area for roll-off boxes, intermodal containers or other waste transport containers

• Exclusion zone (EZ) – decontamination and stockpile area(s) o Access roads o Decontamination pad(s) o Soil stockpile (staging) area(s) o Portable air monitoring stations

• EZ – excavation areas o Access roads o Portable air monitoring stations

• Site-wide and perimeter o Security staff and/or camera(s) o Air monitoring stations o Erosion and sedimentation control features

6.1.1.4.2 Applicable Guide Specifications and Technical Requirements

01 01 01 (REAL ESTATE), 01 35 26 (GOVERNMENTAL SAFETY REQUIREMENTS), 01 35

29.13 (HEALTH, SAFETY, & EMERGENCY RESPONSE PROCEDURES FOR

CONTAMINATED SITES), 01 45 00.00 10 (QUALITY CONTROL), 01 45 00.15 10

(RESIDENT MANAGEMENT SYSTEM CONTRACTOR MODE [RMS CM]), 01 50 00

(TEMPORARY CONSTRUCTION FACILITIES AND CONTROLS), 01 57 23

(TEMPORARY STORM WATER POLLUTION CONTROL) and 01 58 00 (PROJECT

IDENTIFICATION).

Contract W912P422R0015 Section C Technical Scope

17 November 2022

6.1.1.4.3 Proposal Requirements

Identify the following:

• Temporary construction facilities and controls that will be installed on-site

• Sizes, capacities, and technical features where appropriate

• Installation and operation dates

6.1.1.5 Construct Temporary Utilities (331XX0105)

6.1.1.5.1 Work Requirements

Provide utility services (electric, phone, Internet, water [potable and non-potable], sanitary sewage and trash removal).

6.1.1.5.2 Applicable Guide Specifications

01 50 00 (TEMPORARY CONSTRUCTION FACILITIES AND CONTROLS).

6.1.1.5.3 Proposal Requirements

Identify the following:

• Sources of water and how it will be provided

• When utility…