A.03.09 Appendix L - Ph I ESA report_Portsmouth LPP_final_07 Apr 2020.pdf

Phase I Environmental Site Assessment of Proposed Bentonite Slurry Disposal Site and

City Ballfield Complex Property Portsmouth-New Boston Local Protection Project

Portsmouth, Ohio

Final – April 2020

Report of Phase I Environmental Site Assessment Portsmouth Segment of the Portsmouth-New Boston Local Protection Project

Portsmouth, Scioto County, Ohio April 2020

Table of Contents

1.0 Introduction

1.1 Scope of Work

1.2 Investigation Limitations

2.0 Site Description and Investigative Findings

3.0 Records Review

3.1 Ownership History

3.2 Federal and State Records

4.0 Findings

4.1 Field Investigation

4.2 Interviews

4.3 Review of Federal and State Regulatory Records - EDR® Database Search Report

4.4 Historical Topographic Maps and Aerial Photography

5.0 Recommendations

6.0 Environmental Professional Qualifications

7.0 References

Appendices

Appendix A – Project Location Map Appendix B – Site Reconnaissance Photographs Appendix C – Records of Federal and State Regulatory Agencies Appendix D – Records of Interviews Appendix E – Sample Analysis Results

Executive Summary

Introduction

The Portsmouth segment of the Portsmouth/New Boston Local Protection Project is located in Scioto County, Ohio, on the right descending bank of the Ohio River at the mouth of the Scioto River. The Portsmouth segment of the Portsmouth/New Boston LPP levee system was designed and constructed by the U.S. Army Corps of Engineers (USACE) and then turned over to the City of Portsmouth for ownership, operation, and maintenance on May 15, 1950. The Portsmouth LPP levee system is an urban flood risk reduction project providing flood risk management equal to the maximum flood of record, that of 1937 with three-foot freeboard, for the City of Portsmouth, Ohio.

The Ohio River experienced a flood event which reached the crest in the Huntington District during February 19 to 21, 2018. The Governor of the State of Ohio issued an emergency proclamation on February 24, 2018, covering 18 counties, including Scioto County. A Federal Disaster Declaration was made for this flood event on April 17, 2018.

The damages to the Portsmouth Segment of the Portsmouth/New Boston Local Protection Project due to the February and March 2018 flood events are eligible for repair under the Public Law (PL) 84-99 program. The recommended alternative, Alternative 2, is to construct a cut-off wall at the levee crest. The cut-off wall would reduce the likelihood of foundation damages worsening and leading to a possible eventual breach.

Environmental professionals of the Environmental and Remediation Section of the Huntington District, United States Army Corps of Engineers (CELRH EC-CE) conducted Phase I Environmental Site Assessments (ESAs) of sites identified for use in support of the LPP Project’s construction. Personnel also assessed the discharge piping at Pump Station No. 5, which is set to be repaired and/or replaced under the LPP project.

The purpose of the Phase I ESA was to identify recognized environmental conditions (RECs) on or near the Project sites, and was performed in accordance with ASTM Standards E1527-13 and E1528-14, USACE Hazardous, Toxic and Radioactive Waste (HTRW) policies and CELRH-EC ISO 9001 requirements.

Aboveground Discharge Piping Investigation

EC-CE environmental professionals assessed the exterior condition of the aboveground discharge piping at Pump Station No. 5 on June 21, 2018. The discharge pipes have a deteriorating, asphaltic-like coating and metal couplings that bind the pipes together, which had flaking, blue paint. The scope of the LPP project includes removing portions of the piping and installing new pipe. Samples of the blue paint were analyzed and found to contain lead at 4,400 µg/g, or 4,400 parts per million (ppm). The asphaltic pipe coating testing results showed the coating contained asbestos at concentrations of 2% and 4% in two samples which were analyzed.

The pipe repair contractor’s Accident Prevention Plan (APP) shall need to include hazard-specific plans in the APP appendices for Lead Compliance and Asbestos Hazard Abatement, per USACE EM 385-1-1, SAFETY AND HEALTH REQUIREMENTS, 30 Nov 2014, strictly following the guidance in Section 6.C. Lead and Asbestos Hazard Control. Removal and offsite disposal of any lead-based paint and asbestos-containing material generated during the piping repairs shall have to be performed by licensed, qualified personnel, whom have the appropriate certifications, training, personal protective equipment and are enrolled in the required medical surveillance program. Any lead-based paint and asbestos-containing material wastes generated during the discharge piping repair, shall need to be properly containerized, analyzed, manifested and disposed offsite at the appropriate waste disposal facility, in accordance with applicable federal, state and local regulations, laws and/or codes.

EC-CE environmental professionals reviewed environmental records of the sites identified for Project construction use prior to the February 13, 2020 and March 26, 2020 field reconnaissance.

The records listed recognized environmental conditions as provided from various regulatory agencies. Historical aerial photographs and current USGS 7.5-minute topographic maps were also provided in the database report and reviewed prior to the site reconnaissance.

Phase I Environmental Site Assessment Investigative Findings & Recommendations

EC-CE environmental professionals interviewed the city’s wastewater director on February 13, 2020 to gather information regarding any potential environmental issues with the city’s Buckeye Park ballfield complex, proposed for various LPP Project construction purposes, and a site to the north, which had been identified for potential bentonite slurry disposal. The director said that the Buckeye Park site was donated to the city by the Labold family in the 1940’s, formerly known as “Labold Field”. He said that the city has dumped utility trench spoils at the proposed bentonite slurry disposal site. The city’s service director said the city has disposed of tree branches and other soils at that site, but are now trying to clean up the site. EC-CE personnel mentioned that an environmental database report listed the proposed bentonite slurry disposal site as the former “Portsmouth City Dump”, but neither gentlemen had knowledge of the dump’s prior existence.

Site reconnaissance of the proposed bentonite slurry disposal site on February 13, 2020 confirmed the presence of the surficial dumping described by the wastewater director. Concrete rubble, tree and brush spoils, discarded wooden pallets and building materials, plastic sewer/water pipe, waste soil piles, and miscellaneous household refuse was observed. The environmental database report documented that this site was a historic landfill, named the “Portsmouth City Dump”, which operated from 1946 until 1972 when it was closed “pre-rule”, or prior to landfill rules. This site cannot be used for slurry disposal due to its former use as a dump; no excavation or disposal activities can be conducted at this site.

No RECs were observed during the March 26, 2020 site reconnaissance of the city’s Buckeye Park ballfield complex. This area is proposed for various purposes in support of the LPP Project’s construction. The complex was in good condition and well-maintained.

The environmental database report listed the proposed bentonite slurry disposal site as the former “Portsmouth City Dump”, a facility which had closed “pre-rule” in 1972. Due to restrictions from this closure, no construction activities are allowed at the site. The report had records of several sites within the vicinity of the Buckeye Park complex; however, they had all been closed, with no further action required. These sites are not an environmental concern to the Project.

Historical aerial photographs of the proposed bentonite slurry disposal site document the dump and landfilling operations over the years up to site closure in 1972. The historic aerial photographs of the city’s Buckeye Park ballfield complex documented the presence of the football stadium and other ballfields as early as 1947. Park expansion is shown through the years that followed. Nothing was interpreted to be an environmental concern in the historic photographs which were reviewed for the area on or around the Buckeye Park site.

Acronym List

AST Aboveground Storage Tank ASTM American Society for Testing and Materials CELRH EC-CE Environmental and Remediation Section of the Huntington

District, United States Army Corps of Engineers CERCLIS Comprehensive Environmental Response Compensation and

Liability Information System EDR® Environmental Data Resources EM Engineering Manual EPCRA Emergency Planning and Community Right to Know Act ER Engineering Regulations ERNS Emergency Response Notification System ESA Environmental Site Assessment FIFRA Federal Insecticide, Fungicide and Rodenticide Act FINDS Facility Index System HTRW Hazardous, Toxic, and Radioactive Waste NPL National Priorities List QCP Quality Control Plan RCRIS-LQG Resource Conservation and Recovery Information System – Large

Quantity Generators RCRIS-SQG Resource Conservation and Recovery Information System – Small

Quantity Generators RCRIS-TSD Resource Conservation and Recovery Information System –

Treatment, Storage and Disposal Facilities REC Recognized Environmental Concern SHWS State Hazardous Waste Sites SSHP Site Safety and Health Plan SWF/LF Solid Waste Facility/Landfill Facilities TSCA Toxic Substances Control Act USACE United States Army Corps of Engineers USGS United States Geological Service UST Underground Storage Tank

1.0 Introduction

The Portsmouth segment of the Portsmouth/New Boston Local Protection Project is located in Scioto County, Ohio, on the right descending bank of the Ohio River at the mouth of the Scioto River. The Portsmouth segment is located at about Ohio River Mile 355. The Portsmouth segment of the Portsmouth/New Boston LPP levee system was designed and constructed by the U.S. Army Corps of Engineers (USACE) and then turned over to the City of Portsmouth for ownership, operation, and maintenance on May 15, 1950. The Portsmouth LPP is an urban flood risk reduction project providing flood risk management equal to the maximum flood of record, that of 1937 with three-foot freeboard, for the City of Portsmouth, Ohio.

The Ohio River experienced a flood event which reached the crest in the Huntington District during February 19 to 21, 2018. The Governor of the State of Ohio issued an emergency proclamation on February 24, 2018, covering 18 counties, including Scioto County. A joint preliminary damage assessment conducted by local, state and federal emergency management officials in mid-March, documented damages to county, village and township roads, and public buildings totaling $44,000,000. A Federal Disaster Declaration was made for this flood event on April 17, 2018.

The local sponsor, the city of Portsmouth, OH, contacted the Huntington District USACE on March 29, 2018 regarding damages to the levee as a result of high water during the February 2018 flood event. The damages to the Portsmouth Segment of the Portsmouth/New Boston Local Protection Project due to the February and March 2018 flood events are eligible for repair under the Public Law (PL) 84-99 program. The recommended alternative, Alternative 2, is to construct a cut-off wall at the levee crest. The cut-off wall would reduce the likelihood of foundation damages worsening and leading to a possible eventual breach.

Environmental professionals of the Environmental and Remediation Section of the Huntington District, United States Army Corps of Engineers (CELRH EC-CE) conducted Phase I Environmental Site Assessments (ESAs) of sites identified for use in support of the LPP Project’s construction. Personnel also assessed the discharge piping at Pump Station No. 5, which is set to be repaired and/or replaced under the LPP project.

Phase I ESAs are performed to identify recognized environmental conditions (RECs) which may exist on or near the Project sites to ensure that the Government does not acquire contaminated property or expose contractors to potential contamination. Phase I ESAs are intended to identify any RECs prior to any design phase and cost developments for any USACE project.

The Phase I ESA for the Portsmouth – New Boston LPP project was conducted in accordance with ASTM Standards E1527-13 and E1528-14, USACE Hazardous, Toxic and Radioactive Waste (HTRW) policies and CELRH-EC ISO 9001 requirements.

1.1 Scope of Work

Maps showing the location of the proposed LPP Project sites were used to obtain federal and state records of environmentally sensitive incidents and activities in the immediate vicinity of the property. Federal and state databases were accessed through a commercial database retrieval company and are available in Appendix C.

The site reconnaissance for each of the Project sites consisted of a site visit to inspect the condition of the site and adjacent properties with regard to RECs. The ground surfaces were examined for signs of contamination during the onsite reconnaissance. Stained soil, stressed vegetation, surface debris, underground storage tank (UST) fill caps or vent lines, unmarked drums, construction debris like discarded building materials, spilled liquids, fill material, odors, and unusual ground depressions or formations are indicators of possible environmental contamination. The reconnaissance also included the assessment of the potential for contamination due to activities on adjacent properties. Color photographs were taken during the site reconnaissance and are provided in Appendix B.

The City of Portsmouth’s Director of Wastewater and the Services Director were interviewed to determine any information they had of the Project sites’ histories or any environmental issues which might exist. The former Portsmouth City Dump and bentonite slurry disposal was discussed with the Ohio Environmental Protection Agency, Ohio EPA.

In accordance with USACE HTRW Policy, the Quality Control Plan (QCP) and Site-Specific Safety and Health Plan (SSHP) which CELRH-EC-CE previously prepared for Phase I ESAs were implemented prior to and during all phases of this Phase I ESA.

1.2 Investigation Limitations

The purpose of the Phase I ESA was to provide information on the environmental conditions of the project site and adjacent properties to make informed project decisions. A Phase I ESA can reduce, but not eliminate, uncertainty regarding the potential for RECs in connection with the site. The Phase I ESA was performed solely on the information available to EC-CE at the time of the investigation. The conclusions for this report are based on information obtained from federal and state environmental records, public records, and interviews. Visual observations related to hazardous materials or wastes on the sites only represent identified conditions at the time of the site visit. EC-CE cannot provide any warranties or certifications concerning the accuracy or completeness of the information reviewed during the investigation. Phase I ESAs do not include sampling, testing, and/or analyses to conclusively ascertain that contamination exists or is absent at or near the project site.

The determination of potential contamination should not be considered as a definite assertion that an environmentally sensitive condition actually exists. The conclusions and recommendations presented herein are based on information gathered using that degree of care and skill ordinarily exercised under similar circumstances by a competent member of the environmental profession and no warranties are expressed or implied.

2.0 Site Description and Investigative Findings

Pump Station No. 5 Discharge Piping Exterior Coating and Metal Couplings

EC-CE environmental professionals performed a site assessment of the aboveground discharge piping’s exterior coating and metal couplings that bind the pipes together at Pump Station No. 5 on June 21, 2018. The discharge pipes have a deteriorating, asphaltic-like coating and the metal couplings, which bind the pipes together, are painted with a blue-colored, flaking paint. Samples of the blue paint and pipe coating were submitted to a laboratory for chemical analysis. The blue-paint contained lead at 4,400 µg/g, or 4,400 parts per million (ppm). Lead is regulated under OSHA standards 29 CFR 1910.1025 and 29 CFR 1926.62. The asphaltic outer coating contained asbestos, at 2% and 4% in two samples. Asbestos is regulated under OSHA standards 29 CFR 1910.1001, 29 CFR 1926.1101 and 40 CFR 6. Sample analysis results are provided in Appendix E.

Pump Station No. 5 Discharge Piping Coating and Metal Couplings

Proposed bentonite slurry disposal area

EC-CE environmental professionals performed an onsite assessment of the proposed bentonite slurry disposal site on February 13, 2020. Environmental database records were reviewed prior to the site reconnaissance. During the site reconnaissance, the ground surfaces on the targeted Project sites and on adjacent properties were examined for signs of environmental contamination or concern. The surficial dumping described by the wastewater director was observed, with the presence of concrete rubble, tree and brush spoils, discarded wooden pallets and building materials, plastic sewer/water pipe, waste soil piles, and miscellaneous household refuse.

View of former Portsmouth City Dump – February 13, 2020 Proposed Bentonite Slurry Disposal Site

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Void

H1ECXRSE

Void

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Void

Bentonite slurry disposal involves excavating a large pit, potentially 20-feet deep, and then mixing waste bentonite slurry and soil until the material in the pit ‘solidifies’.

Portsmouth, OH, City Ballfield Complex, Buckeye Park

EC-CE reviewed a draft Project site plan, which depicted various proposed uses of the city’s Buckeye Park ballfield complex for the construction of the LPP Project, prior to site reconnaissance. Buckeye Park, formerly named “Labold Field”, is located south of Williams Street and to the west of the city’s Pump Station No. 5, Portsmouth, OH. Several baseball/softball fields and a football stadium are located on the property. The ballfield complex consists of four (4) large tracts of land, which were undeveloped at the time the Labold family donated the property to the City of Portsmouth in the 1940’s. Since that time, the city has constructed a football stadium and developed a ballfield complex, and the site is known as Buckeye Park. EC-CE environmental professionals performed the site reconnaissance of Buckeye Park on March 26, 2020 and observed no RECs during the site assessment.

View of proposed Clay Stockpile Area March 26, 2020

Polygonal Line

Proposed Multi-Project Use Area to West of Football Stadium

Photographs from the three site reconnaissance visits are provided in Appendix B.

3.0 Records Review

3.1 Ownership History

Sufficient information was obtained on the prior use, history and records obtained in the environmental database report, that ownership research was determined not necessary for this Phase I ESA. The site which had been tentatively identified for bentonite slurry disposal cannot be used due its former use as the “Portsmouth City Dump”. That site was closed under landfill “pre-rule” requirements, which restricts excavation and other uses of the property. At the time of the site reconnaissance of the city’s Buckeye Park ballfield complex site, deed/ownership research had not been conducted; however, access to the Scioto County, OH courthouse records was restricted due to current COVID-19 concerns. It was determined, though, from the interviews with the city’s wastewater director and services director, that the city’s ballfield complex property was undeveloped land prior to being donated to the city in the 1940’s.

Additional information in the environmental database report also provided adequate documentation of past property use, to determine there had been no past uses which would have been an environmental concern.

3.2 Federal and State Records

Records of regulatory agencies listing recognized environmental conditions in connection with the proposed bentonite slurry disposal site, the city’s ballfield complex site and adjacent properties were obtained from Environmental Data Resources (EDR®), a commercial data retrieval company in Southport, CT. The EDR® environmental database reports are included in Appendix C and include information from the following databases:

3.2.1 Federal Databases

A search distance of 1.0 miles from the proposed bentonite slurry disposal site and the city’s ballfield complex site was used for research into federal agency databases, which include but not limited to, the following:

NPL National Priority List Proposed NPL Proposed National Priority List Sites CERCLIS Comprehensive Environmental Response, Compensation, and Liability

Information System CERC-NFRAP CERCLIS No Further Remedial Action Planned CORRACTS Corrective Action Report RCRIS-TSD Resource Conservation and Recovery Information System – Treatment, Storage and Disposal Facilities RCRIS-LQG Resource Conservation and Recovery Information System – Large

Quantity Generators RCRIS-SQG Resource Conservation and Recovery Information System – Small

Quantity Generators ERNS Emergency Response Notification System MINES Mines Master Index File TRIS Toxic Chemical Release Inventory System TSCA Toxic Substances Control Act FTTS FIFRA/TSCA Tracking System

3.2.2 State Databases

A search distance of 1.0 miles from the proposed bentonite slurry disposal site and the city’s ballfield complex site was used for research into state databases, which include but not limited to, the following:

KY SHWS State Hazardous Waste Sites.

SWF/LF State Solid Waste Facilities/Landfill List KY UST Registered Underground Storage Tanks Database KY LUST Leaking Underground Storage Tanks KY VCP Voluntary Cleanup Program Sites SPILLS Spills Listing DRYCLEANERS Listing of Drycleaner Locations

4.0 Findings

4.1 Field Investigation

EC-CE environmental professionals performed a site assessment of the aboveground discharge piping at Pump Station No. 5 on June 21, 2018. EC-CE performed site assessments of the proposed bentonite slurry disposal area on February 13, 2020 and of the city’s Buckeye Park ballfield complex on March 26, 2020, for this Phase I ESA. Photographs are provided in Appendix B. Observations from the reconnaissance are discussed in Section 2.0.

4.2 Interviews

Mr. Richard Duncan, the city of Portsmouth’s wastewater director, and Mr. Jack Tackett, the city’s service director, were interviewed on February 13, 2020. EC-CE asked the interviewees if they had any knowledge of former and current property ownership and site uses, for the city’s Buckeye Park ballfield complex and the site identified for bentonite slurry disposal. Mr. Duncan said the Labold family had donated the current city ballfield site to the city in the 1940’s, and the site was previously known as “Labold Field”. He said that the city has dumped utility trench spoils on the surface of the proposed bentonite slurry disposal site, and referred to the site as the “Bertha Dump”, noted from nearby Bertha Avenue which provides accesses to the site. Mr.

Tackett said the city has disposed of tree branches and other soils at the Bertha Dump, but the city is now working to clean up the site. EC-CE personnel mentioned the record in the EDR® report which documented the site as the former “Portsmouth City Dump”, which had operated from the 1940’s and was closed “pre-rule” in 1972, but neither gentlemen had knowledge of the dump’s prior existence.

EC-CE personnel interviewed Mr. Rick Fox of the Southeast District Office (SEDO), Ohio Environmental Protection Agency (Ohio EPA), on February 18, 2020, following the field reconnaissance of the proposed bentonite slurry disposal site. Mr. Fox said he had no records of the former Portsmouth City Dump, but the site cannot be used for slurry disposal due to its former use as the Portsmouth City Dump, and being closed, “pre-rule”. Under “pre-rule” closure, the city of Portsmouth was able to “walk away” from the site, with no closure requirements; no excavation or disposal activities can be conducted at this site.

No potential RECs were determined from these interviews. Refer to Appendix D for the interview records.

4.3 Review of Federal and State Regulatory Records - EDR® Database Search Report

The environmental database report was reviewed and results are discussed in the following sections. The complete EDR® database search report is in Appendix C.

4.4.1 Orphan Sites

One orphan site, the Flood Defense Pump Station at 12th Street, Portsmouth, OH, was identified within the search radius of the proposed bentonite slurry disposal site. There were no records of environmental concern in the EDR report and this site does not appear to be an environmental concern for the proposed bentonite slurry disposal site.

One orphan site, Wilson’s Used Parts, James Hannah Drive, South Shore, OH was identified within the search radius of the city’s Buckeye Park. This site is located south of and across the Ohio River from Buckeye Park and due to its location, is not an environmental concern for the proposed bentonite slurry disposal site

4.4.2 Environmental Database Findings

The EDR® report documented that the proposed bentonite slurry disposal site was a historic landfill, formerly named the “Portsmouth City Dump”. The record indicted that the dump operated from 1946 until 1972, when it was closed prior to landfill rules, i.e., “pre-rule”.

The environmental database report listed four (4) underground storage tank (UST)/leaking underground storage tank (LUST) sites within 1/4 to 1/2 mile of the city’s Buckeye Park site.

All of these UST/LUST sites were closed with no further action and are therefore not an environmental concern to the Project. An historic landfill site is located within 1/2 mile to the east, which disposed foundry sand. The environmental database report noted the disposal ceased in 1997 and no further action was documented for this landfill. That site is not an environmental concern to the Project site.

4.4 Historical Topographic Maps and Aerial Photography

Per ASTM E 1527-13, Section 7.3 on historical use information, a review of reasonably ascertainable standard historical sources was performed as a part of this Phase I ESA. The purpose of a historical records search is to determine the past uses of the tract. The current and historical USGS 7.5-minute topographic maps were available for examination. Historical aerial photographs were also reviewed. Copies of the USGS topographic maps and aerial photos are included with the EDR® report in Appendix C.

The topographic maps for the proposed bentonite slurry disposal site cover the period 1911 – 2013. Little information was detailed in the maps until the 1974, 1975 map. That map shows the proposed bentonite slurry disposal site, but there is little other detail, other than a small water body shown near the site. A Norfolk and Western rail line lies to the east. All other topographic maps had little detail or have major portions shown as “Unmapped” on the file. No RECs were determined from review of the topographic maps for this site or any adjacent properties.

The topographic maps for the city’s Buckeye Park ballfield complex site cover the period 1911 – 2013. The 1911 – 1916 map largely shows the area as ‘vacant or undeveloped’. No major changes are documented in the 1930 map. The 1951, 1953 map first shows the site’s name as “Labold Field”. Pump Station No. 5 is visible to the east of the site. The areas which are currently residential, first show on this map. There is scattered development in the vicinity. A large rail yard is present approximately one mile to the northeast of Labold Field. The football stadium first shows in the 1968 map and the sewage disposal facility is noted to the east of the site. The 1974, 1975 map shows a new building to the west of the football stadium, possibly the city garage. There is other expansion noted. The 2013 map has no detail, other than the site’s name, “Labold Field”. No RECs were determined from review of the topographic maps for the area on or adjacent to the city’s Buckeye Park, ballfield complex.

Little detail can be found in the maps prior to the 1963 topographic map. A high school is depicted east of the project site and sporadic residential development is detailed on the 1963 map. State Route 652 which runs adjacent to the project site is present. The 1977 topographic map shows surface mines to the north and south of the project site, approximately one mile away in either direction. Due to distance of these features from the project site, and streams or rivers located between the mines and the project site, these surface mines were determined to pose no environmental concern. The 2013 topographic map has very little detail and was not usable for this Phase I ESA.

The historical aerial photographs of the proposed bentonite slurry disposal site documented extensive ground disturbance from city dump activities from 1947 to 1967. Then through the 1994 aerial photograph, the surface activity subsided and vegetative growth began to cover the site; however, the 2001 through 2017 photographs documented increasing surface disturbance.

Historical aerial photographs of the city’s Buckeye Park ballfield complex from 1947 to 2017 documented the football stadium and other ballfields as early as 1947. The large tract of land west of the football stadium was undeveloped and Pump Station No. 5 is visible in the 1947 photograph. The remaining photographs through 2017 show an increased number of ballfields to the east, new ballfields to the west of the football stadium, the foundry sand disposal site, and the salt stockpile east of the storm water pumping station. None of the historic aerial photographs had any features which were interpreted to be of an environmental concern to the Project.

The Sanborn® Map Company, the best known of the US fire-insurance map producers, has made maps since 1867. The historic fire insurance maps produced by Sanborn® show building footprints, building material, height or number of stories, building use, lot lines, road widths and water facilities. The maps also show street names and property boundaries of the time.

Sanborn® maps were available and reviewed, but no information was documented which would indicate a potential REC at either Project site.

5.0 Recommendations

Aboveground Discharge Piping

The discharge pipes at Pump Station No. 5 have a deteriorating, asphaltic-like coating and the metal couplings which bind the pipes together have a flaking, blue paint. The scope of the LPP project includes removing/repairing portions of the piping and installing new pipe. The blue paint contains lead and the pipe coating contains asbestos in regulated concentrations. Lead is regulated under OSHA standards 29 CFR 1910.1025 and 29 CFR 1926.62. Asbestos is regulated under OSHA standards 29 CFR 1910.1001, 29 CFR 1926.1101 and 40 CFR 6.

Lead and asbestos are regulated under several OSHA rules; therefore, the pipe repair contractor’s Accident Prevention Plan (APP) shall need to include hazard-specific plans in the APP appendices for Lead Compliance and Asbestos Hazard Abatement, per USACE EM 385-1-1, SAFETY AND HEALTH REQUIREMENTS, 30 Nov 2014, strictly following the guidance in Section 6.C. Lead and Asbestos Hazard Control.

Removal and offsite disposal of any lead-based paint and asbestos-containing material generated during the piping repairs shall be performed by licensed, qualified personnel, whom have the appropriate certifications, training, personal protective equipment and are enrolled in the required medical surveillance program. Those contractors shall submit their plans for lead-based paint and asbestos-containing material removal, providing personnel qualifications and their means and methods to protect their workers, other site personnel and prevent the spread of these wastes to the environment during the discharge piping repairs.

Any lead-based paint and asbestos-containing material wastes generated during the discharge piping repair, shall be properly containerized, analyzed, manifested and disposed offsite at the appropriate waste disposal facility, in accordance with applicable federal, state and local regulations, laws and/or codes.

Proposed Bentonite Slurry Disposal Site

Records research and the February 13, 2020 site reconnaissance performed for this Phase I ESA found that the proposed bentonite slurry disposal site is the former Portsmouth City Dump. The site was closed prior to landfill regulations, i.e., “pre-rule”; therefore, no construction activities are allowed and this site cannot be used for Project bentonite slurry disposal.

Buckeye Park Ballfield Complex Site

Interviews and records research conducted for the city’s ballfield complex site determined that the property was undeveloped land up to the 1940’s, when the Labold Family donated the property to the city of Portsmouth. Historic aerial photography confirmed the presence of a football stadium and other ballfields as early as 1947. The March 26, 2020 site reconnaissance confirmed the continued use as a ballfield complex. No RECs were determined from the Phase I ESA of this site; therefore, there is no evidence that there are any environmental concerns for the proposed LPP Project construction purposes.

6.0 Environmental Professional Qualifications

I, Frank R. Albert, Jr., P.E., have the specific qualifications based on education, training, and experience to assess a property of the nature, history, and setting of the subject property. I have developed and performed the all appropriate inquiries in conformance with the standards and practices set forth in 40 CFR Part 312.

I declare that, to the best of my professional knowledge and belief, I meet the definition of Environmental Professional as defined in §312.10 of this part.

Relevant Education:

BS, Civil Engineering, Virginia Tech, 1979 Post-graduate Masters’ Degree studies in Engineering Management Training in Environmental Regulations and Law, Environmental Remediation

Relevant Experience:

1984-present, Civil Engineer/Environmental Engineer, US Army Corps of Engineers – Perform environmental site assessments and plan and manage environmental investigation and remediation of residential, commercial, and formerly used military sites.

1984-present, Registered Professional Engineer, WV, #9589

Frank R. Albert, Jr., P.E. Date Environmental Engineer WV Professional Engineer License #9589

07 April 2020

7.0 References

ASTM E 1527-13, Standard Practices for Environmental Site Assessments: Phase I Environmental Site Assessment Process. (November 1, 2013).

ASTM E 1528-14, Standard Practices for Environmental Site Assessments: Transaction Screening Process. (January 15, 2014).

CEORD-RE Memorandum dated 26 July 1994; subject: Policy for Acquiring Lands with Known or Suspected USTs. (July 26, 1994).

EM 200-1-2, Technical Project Planning Guidance for HTRW Data Quality Design. (February 22, 2016).

EM 385-1-1, Safety and Health Requirements Manual. (November 30, 2014).

ER 1165-2-132, Hazardous, Toxic, and Radioactive Waste (HTRW) Guidance for Civil Works Projects. (June 26, 1992).

USACE QMS Qualtrax, Work Instruction 08620.02 LRH – Phase I Environmental Site Assessments, (February 27, 2018).

http://ecpub.lrh.usace.army.mil/ec/ecm/ecmq/ISO/Controlled%20Documentation/LV%203%20Work%20Instructions/WI%20WORD%20Files/Construction%20PDF%20Files/E1527-00.pdf http://ecpub.lrh.usace.army.mil/ec/ecm/ecmq/ISO/Controlled%20Documentation/LV%203%20Work%20Instructions/WI%20WORD%20Files/Construction%20PDF%20Files/E1527-00.pdf http://ecpub.lrh.usace.army.mil/ec/ecm/ecmq/ISO/Controlled%20Documentation/LV%203%20Work%20Instructions/WI%20WORD%20Files/Construction%20PDF%20Files/E1528-00.pdf http://ecpub.lrh.usace.army.mil/ec/ecm/ecmq/ISO/Controlled%20Documentation/LV%203%20Work%20Instructions/WI%20WORD%20Files/Construction%20PDF%20Files/E1528-00.pdf http://ecpub.lrh.usace.army.mil/ec/ecm/ecmq/ISO/Controlled%20Documentation/LV%203%20Work%20Instructions/WI%20WORD%20Files/Construction%20PDF%20Files/CEORD-RE%20UST%20Policy%207_26_94.pdf http://ecpub.lrh.usace.army.mil/ec/ecm/ecmq/ISO/Controlled%20Documentation/LV%203%20Work%20Instructions/WI%20WORD%20Files/Construction%20PDF%20Files/CEORD-RE%20UST%20Policy%207_26_94.pdf http://www.usace.army.mil/inet/usace-docs/eng-manuals/em200-1-2/toc.htm http://www.usace.army.mil/inet/usace-docs/eng-manuals/em385-1-1/toc.htm http://www.usace.army.mil/inet/usace-docs/eng-regs/er1165-2-132/toc.htm http://www.usace.army.mil/inet/usace-docs/eng-regs/er1165-2-132/toc.htm

APPENDIX A

Project Location Map

Proposed Bentonite Slurry Disposal Site Site of former “Portsmouth City Dump”

H1ECXRSE

Void

Pump Station No. 5 Project borrow, spoil, stockpile and storage site

CHARLES

STREET

B R

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RELOCATION OPERATIONS

SANITARY SEWER DISCHARGE

RAMP

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PUMP STATION No. 5

OPERATION

PUMPING

BYPASS

TRAILER

TRAILER

TRAILER

TRAIL

ER

TRAIL

ER

CLAY (15' TALL)

STOCKPILE FOR EARTHWORK

30°

60°

90°

90°

30°

60°

90°

SLURRY PONDS

STOCKPILE

TEMPORARY SPOIL

180°

90°

TOPSOIL

STOCKPILE FOR EARTHWORK

DISPOSAL AREA

BORROW AND SLURRY

DISPOSAL AREA

BORROW AND SPOIL

EQUIPMENT LAYDOWN AREA

CONSTRUCTION TRAFFIC /

PIPE REPLACEMENT

PUMP STATION DISCHARGE

FIELD OFFICE

WELDING SHOP

MAINTENANCE /

TRAILER

TRAILER

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A

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CONEX BOX

SITE OFFICE

LAB OFFICE

OFFICE

SAFETY

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AGGREGATE

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FIELD OFFICE

CONEX BOX CONEX BOX

GENERATOR AND STORAGE

MATERIAL STORAGE

PLANT OPERATION

JET GROUT BATCH OPERATION

BELT PRESS

OHIO RIVER

FLOW

N

DISCHARGE

TREATMENT PLANT

16'' WASTEWATER

CEMENTIOUS SILOS

CHILLER/BOILER, COLOR DOSING,

LOADING BINS, CHEM DOSING,

ALIGNMENT

SEEPAGE BARRIER

D

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N: 265705.700

09-25-2019 (INVERT ELV=484.72)

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Information Only

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APPENDIX B

Site Reconnaissance Photographs

Portsmouth Local Protection Project

June 2018

Photo 1 – Pump Station No. 5 Discharge Piping

Photo 2 – Pump Station No. 5 Discharge Piping Coating and Metal Couplings

February 13, 2020

Photo 3 - View Northeast along Storm Sewer Replacement Alignment

Photo 4 – View Southwest across Possible Contractor Laydown Area and Ramp to Levee

Photo 5 – Entrance to Former Portsmouth City Dump

Photo 6 – Waste Soil, Water/Sewer Pipe, Brush and Household Refuse

Void

Photo 7 – View Across former Portsmouth City Dump from Levee

Photo 8 – View Across former Portsmouth City Dump from Levee

Void

Portsmouth, Scioto County, Ohio

March 26, 2020

Photo 9 – View West across Clay Stockpile Area

Photo 10 – View Southwest across Clay Stockpile Area

Portsmouth, Scioto County, Ohio

March 26, 2020

Photo 11 – View South across Slurry Ponds Area

Photo 12 – View North across Jet Grout Plant Operations

Portsmouth, Scioto County, Ohio

March 26, 2020

Photo 13 – View Northwest across Belt Press Operation Site

Photo 14 – View South across Aggregate and other Material Storage Area

Photo 15 – View Southwest towards Topsoil Stockpile Area

Photo 16 – View West across Laydown Area and Material and Generator Storage Yards

APPENDIX C

Records of Federal and State Regulatory Agencies

(EDR® Report)

FORM-LBC-MGA

®kcehCoeG htiw tropeR ™paM suidaR RDE ehT

6 Armstrong Road, 4th floor Shelton, CT 06484 Toll Free: 800.352.0050 www.edrnet.com

Portsmouth OH Slurry Disposal Rt 23 and 18th Street Portsmouth, OH 45662

Inquiry Number: 5955272.2s January 31, 2020

SECTION PAGE

Executive Summary ES1

Overview Map 2

Detail Map 3

Map Findings Summary 4

Map Findings 8

Orphan Summary 36

Government Records Searched/Data Currency Tracking GR-1

GEOCHECK ADDENDUM

Physical Setting Source Addendum A-1

Physical Setting Source Summary A-2

Physical Setting SSURGO Soil Map A-5

Physical Setting Source Map A-12

Physical Setting Source Map Findings A-14

Physical Setting Source Records Searched PSGR-1

TC5955272.2s Page 1

Thank you for your business.

Please contact EDR at 1-800-352-0050 with any questions or comments.

Disclaimer - Copyright and Trademark Notice

This Report contains certain information obtained from a variety of public and other sources reasonably available to Environmental Data Resources, Inc. It cannot be concluded from this Report that coverage information for the target and surrounding properties does not exist from other sources. NO WARRANTY EXPRESSED OR IMPLIED, IS MADE WHATSOEVER IN CONNECTION WITH THIS REPORT. ENVIRONMENTAL DATA RESOURCES, INC. SPECIFICALLY DISCLAIMS THE MAKING OF ANY SUCH WARRANTIES, INCLUDING WITHOUT LIMITATION, MERCHANTABILITY OR FITNESS FOR A PARTICULAR USE OR PURPOSE. ALL RISK IS ASSUMED BY THE USER. IN NO EVENT SHALL ENVIRONMENTAL DATA RESOURCES, INC. BE LIABLE TO ANYONE, WHETHER ARISING OUT OF ERRORS OR OMISSIONS, NEGLIGENCE, ACCIDENT OR ANY OTHER CAUSE, FOR ANY LOSS OF DAMAGE, INCLUDING, WITHOUT LIMITATION, SPECIAL, INCIDENTAL, CONSEQUENTIAL, OR EXEMPLARY DAMAGES. ANY LIABILITY ON THE PART OF ENVIRONMENTAL DATA RESOURCES, INC. IS STRICTLY LIMITED TO A REFUND OF THE AMOUNT PAID FOR THIS REPORT. Purchaser accepts this Report "AS IS". Any analyses, estimates, ratings, environmental risk levels or risk codes provided in this Report are provided for illustrative purposes only, and are not intended to provide, nor should they be interpreted as providing any facts regarding, or prediction or forecast of, any environmental risk for any property. Only a Phase I Environmental Site Assessment performed by an environmental professional can provide information regarding the environmental risk for any property. Additionally, the information provided in this Report is not to be construed as legal advice.

Copyright 2020 by Environmental Data Resources, Inc. All rights reserved. Reproduction in any media or format, in whole or in part, of any report or map of Environmental Data Resources, Inc., or its affiliates, is prohibited without prior written permission.

EDR and its logos (including Sanborn and Sanborn Map) are trademarks of Environmental Data Resources, Inc. or its affiliates. All other trademarks used herein are the property of their respective owners.

TABLE OF CONTENTS

EXECUTIVE SUMMARY

TC5955272.2s EXECUTIVE SUMMARY 1

A search of available environmental records was conducted by Environmental Data Resources, Inc (EDR).

The report was designed to assist parties seeking to meet the search requirements of EPA’s Standards and Practices for All Appropriate Inquiries (40 CFR Part 312), the ASTM Standard Practice for Environmental Site Assessments (E 1527-13), the ASTM Standard Practice for Environmental Site Assessments for Forestland or Rural Property (E 2247-16), the ASTM Standard Practice for Limited Environmental Due Diligence: Transaction Screen Process (E 1528-14) or custom requirements developed for the evaluation of environmental risk associated with a parcel of real estate.

TARGET PROPERTY INFORMATION

ADDRESS

RT 23 AND 18TH STREET

PORTSMOUTH, OH 45662

COORDINATES

38.7463560 - 38˚ 44’ 46.88’’Latitude (North):

82.9963330 - 82˚ 59’ 46.79’’Longitude (West):

Zone 17Universal Tranverse Mercator:

326506.4UTM X (Meters):

4290315.0UTM Y (Meters):

515 ft. above sea levelElevation:

USGS TOPOGRAPHIC MAP ASSOCIATED WITH TARGET PROPERTY

5965654 PORTSMOUTH, OHTarget Property Map:

2013Version Date:

5965402 NEW BOSTON, OHNortheast Map:

2013Version Date:

5964755 FRIENDSHIP, OHSouthwest Map:

2013Version Date:

5964621 WEST PORTSMOUTH, OHNorthwest Map:

2013Version Date:

AERIAL PHOTOGRAPHY IN THIS REPORT

20150821, 20150907, 20150822Portions of Photo from:

USDASource:

5955272.2s Page 2

17 ARCHEM CORP 1514 11TH ST CORRACTS, RCRA NonGen / NLR, ICIS, FINDS, ECHO Higher 4325, 0.819, SE

C16 FORMER RAX RESTAURAN 1130 CHILICOTHE ST LUST, UST Higher 2361, 0.447, South

D15 BUSTERS BI LO #24 1201 GAY ST LUST, UST Higher 2319, 0.439, SSE

D14 BP #08648 1200 GAY ST LUST Higher 2301, 0.436, SSE

C13 CHABOTS #5 1201 CHILLICOTHE ST LUST, UST Higher 2239, 0.424, South

12 CLEVENGER RENTAL INC 1311 FINDLAY ST LUST, UST Higher 2113, 0.400, SSE

11 HACKMAN CO 17TH & ROBINSON LUST Higher 1648, 0.312, ESE

10 PORTSMOUTH DISPOSAL BERTHA AVENUE HIST LF Lower 1634, 0.309, North

9 NORFOLK SOUTHERN 1025 16TH ST LUST Higher 1548, 0.293, SE

B8 BUSTERS #10 1910 SCIOTO TRAIL LUST, UST Higher 1286, 0.244, ENE

B7 SOUTH SHORE GAS AND 1910 SCIOTO TRAIL RCRA NonGen / NLR, FINDS, ECHO Higher 1286, 0.244, ENE

B6 EMRO MARKETING CO 1910 SCIOTO TRAIL ARCHIVE UST, SPILLS Higher 1286, 0.244, ENE

A5 KDMC PORTSMOUTH MEDI 2001 SCIOTO TRAIL AST Higher 1222, 0.231, ENE

A4 KINGS DAUGHTER MEDIC 2001 SCIOTO TRAIL LUST, UST Higher 1222, 0.231, ENE

A3 KDMC PORTSMOUTH MEDI 2001 SCIOTO TRAIL AST Higher 1222, 0.231, ENE

2 KING’S DAUGHTER MEDI 1901 ARGONNE RD SWF/LF Higher 858, 0.162, ENE

1 PORTSMOUTH CITY DUMP HIST LF Lower 310, 0.059, West

MAPPED SITES SUMMARY

Target Property Address:

RT 23 AND 18TH STREET

PORTSMOUTH, OH 45662

Click on Map ID to see full detail.

MAP RELATIVE DIST (ft. & mi.)

ID DATABASE ACRONYMS ELEVATION DIRECTIONSITE NAME ADDRESS

TC5955272.2s EXECUTIVE SUMMARY 3

TARGET PROPERTY SEARCH RESULTS

The target property was not listed in any of the databases searched by EDR.

DATABASES WITH NO MAPPED SITES

No mapped sites were found in EDR’s search of available ("reasonably ascertainable ") government records either on the target property or within the search radius around the target property for the following databases:

STANDARD ENVIRONMENTAL RECORDS

Federal NPL site list

NPL National Priority List Proposed NPL Proposed National Priority List Sites NPL LIENS Federal Superfund Liens

Federal Delisted NPL site list

Delisted NPL National Priority List Deletions

Federal CERCLIS list

FEDERAL FACILITY Federal Facility Site Information listing SEMS Superfund Enterprise Management System

Federal CERCLIS NFRAP site list

SEMS-ARCHIVE Superfund Enterprise Management System Archive

Federal RCRA non-CORRACTS TSD facilities list

RCRA-TSDF RCRA - Treatment, Storage and Disposal

Federal RCRA generators list

RCRA-LQG RCRA - Large Quantity Generators RCRA-SQG RCRA - Small Quantity Generators RCRA-VSQG RCRA - Very Small Quantity Generators (Formerly Conditionally Exempt Small Quantity Generators)

Federal institutional controls / engineering controls registries

LUCIS Land Use Control Information System US ENG CONTROLS Engineering Controls Sites List US INST CONTROL Sites with Institutional Controls

Federal ERNS list

ERNS Emergency Response Notification System

TC5955272.2s EXECUTIVE SUMMARY 4

State- and tribal - equivalent CERCLIS

SHWS This state does not maintain a SHWS list. See the Federal CERCLIS list and Federal NPL list.

DERR Division of Environmental Response and Revitalization Database

State and tribal leaking storage tank lists

INDIAN LUST Leaking Underground Storage Tanks on Indian Land UNREG LTANKS Ohio Leaking UST File

State and tribal registered storage tank lists

FEMA UST Underground Storage Tank Listing INDIAN UST Underground Storage Tanks on Indian Land

State and tribal institutional control / engineering control registries

HIST ENG CONTROLS Operation & Maintenance Agreements Database HIST INST CONTROLS Institutional Controls Database ENG CONTROLS Sites with Engineering Controls INST CONTROL Sites with Institutional Engineering Controls

State and tribal voluntary cleanup sites

INDIAN VCP Voluntary Cleanup Priority Listing VCP Voluntary Action Program Sites

State and tribal Brownfields sites

BROWNFIELDS Ohio Brownfield Inventory

ADDITIONAL ENVIRONMENTAL RECORDS

Local Brownfield lists

US BROWNFIELDS A Listing of Brownfields Sites

Local Lists of Landfill / Solid Waste Disposal Sites

SWRCY Recycling Facility Listing INDIAN ODI Report on the Status of Open Dumps on Indian Lands DEBRIS REGION 9 Torres Martinez Reservation Illegal Dump Site Locations ODI Open Dump Inventory IHS OPEN DUMPS Open Dumps on Indian Land

Local Lists of Hazardous waste / Contaminated Sites

US HIST CDL Delisted National Clandestine Laboratory Register CDL Clandestine Drug Lab Locations US CDL National Clandestine Laboratory Register PFAS PFOA & PFOS Site Listing

Local Land Records

LIENS 2 CERCLA Lien Information

TC5955272.2s EXECUTIVE SUMMARY 5

Records of Emergency Release Reports

HMIRS Hazardous Materials Information Reporting System SPILLS Emergency Response Database SPILLS 90 SPILLS 90 data from FirstSearch SPILLS 80 SPILLS 80 data from FirstSearch

Other Ascertainable Records

FUDS Formerly Used Defense Sites DOD Department of Defense Sites SCRD DRYCLEANERS State Coalition for Remediation of Drycleaners Listing US FIN ASSUR Financial Assurance Information

EPA WATCH LIST EPA WATCH LIST

2020 COR ACTION 2020 Corrective Action Program List TSCA Toxic Substances Control Act TRIS Toxic Chemical Release Inventory System SSTS Section 7 Tracking Systems ROD Records Of Decision RMP Risk Management Plans RAATS RCRA Administrative Action Tracking System PRP Potentially Responsible Parties PADS PCB Activity Database System ICIS Integrated Compliance Information System FTTS FIFRA/ TSCA Tracking System - FIFRA (Federal Insecticide, Fungicide, & Rodenticide Act)/TSCA (Toxic Substances Control Act) MLTS Material Licensing Tracking System COAL ASH DOE Steam-Electric Plant Operation Data COAL ASH EPA Coal Combustion Residues Surface Impoundments List PCB TRANSFORMER PCB Transformer…