B.08 GFI JB CHS PBR_XE005 (SWMU 25)_DF LUCIP.pdf

DEPARTMENT OF THE AIR FORCE

AIR FORCE CIVIL ENGINEER CENTER

JOINT BASE CHARLESTON SOUTH CAROLINA

2 March 2021

Ms. Jennifer L. Burger AFCEC/CZOE, Charleston ISS 203 S. Davis Drive, Bldg 247, 1st Floor Joint Base Charleston, SC 29404-4707

Mrs. Christi Pickett Project Manager RCRA Federal Facilities Section Division of Waste Management Bureau of Land and Waste Management South Carolina Dept. of Health and Environmental Control 2600 Bull Street Columbia, SC 29201

RE: Draft Final Land Use Control Inspection Plan for SWMU 25 (XE005) at Joint Base Charleston

Weapons, South Carolina

Dear Mrs. Pickett

Enclosed please find for your review the Draft Final Land Use Control Inspection Plan for SWMU 25 (XE005) at Joint Base Charleston Weapons, South Carolina.

In accordance with SC R.61-79.270.11(d)(1) SC HAZARDOUS WASTE MANAGEMENT REGULATIONS, I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

Thank you in advance for your consideration. Should you have any questions or comments regarding the enclosure, please contact me by telephone at (843) 963-2708 or by email at jennifer.burger.2@us.af.mil.

Sincerely

Jennifer L. Burger, GS-12, DAFC Restoration Project Manager cc:

AFCEC/CZRE, Tony Williams

Attachment A. SWMU 25 (XE005) LUC INSPECTION WORK PLAN

Uniform Federal Policy Quality Assurance Project Plan

Draft Final March 2021 Revision 00

Basewide Groundwater, Surface Water, and Land Use Control Monitoring

Joint Base Charleston Weapons, Charleston, South Carolina

Prepared Under:

Contract FA8903-15-C-0016

Prepared for:

AFCEC/CZRE

Air Force Civil Engineer Center

772nd ESS/PKS 2261 Hughes Avenue, Suite 155

JBSA Lackland, Texas 78236-9853

Prepared by:

Bay West LLC 5 Empire Drive

St. Paul, Minnesota 55103-1867

(651) 291-0456

With Teaming Partners:

UFP-QAPP Attachment A: SWMU 25 (XE005) LUC Inspection Work Plan Basewide Groundwater, Surface Water, Land Use Control Monitoring

Joint Base Charleston Weapons, South Carolina

Contract FA8903-15-C-0016 1 BWJ140078

1.0 SITE INFORMATION

Site Description

Site Name: Old South Annex Munitions Disposal Area (SWMU 25/XE005)

Site Stage: Long-Term Management (LTM)

Location

Joint Base Charleston (JBC) Weapons is located 10 miles north of Charleston, South Carolina, approximately 16 miles inland from the Atlantic Ocean. The facility is situated in two counties, Berkeley and Charleston, and occupies 16,868 acres. Solid Waste Management Unit (SWMU) 25

– Old South Annex Munitions Disposal Area (hereinafter referred to as “SWMU 25”) is located south of Goose Creek in the South Annex of the base (Figure 1). SWMU 25 is 26.2 acres and includes Burial Area 1, Burial Area 2, Water Range, Unexploded Area, and TC Dock Finger Pier Area. The Surface Deployment and Distribution Command (SDDC) Parking Lot (Staging Area Lot C), which is actively used for military shipping and storage of vehicles and equipment, is within the footprint of SWMU 25. A site map is presented as Figure 2.

SWMU 25 has been divided into two munitions response sites (MRSs) to separate the land and water areas of the site per Military Munitions Response Program (MMRP) guidance. The identification for the land area MRS is XE005 (15.3 acres), and the identification for the water area MRS is XE005A (10.9 acres; Figure 2).

Historical Use

The Army reportedly disposed of unknown types and quantities of munitions at SWMU 25 between 1918 and 1945. Prior to and during the Korean War, steel munitions and ordnance of various types were likely disposed of in this area by excavating pits and backfilling the pits with the ordnance and soil. Burial areas were low-lying areas and wetlands that were filled and graded to several feet above the original elevations.

The former SWMU 28, South Annex Building 3818, is located within the footprint of SWMU 25.

SWMU 28 consisted of five concrete underground storage tanks (USTs) used for industrial waste storage. The USTs were used to collect discharge and other effluent from the buildings. The tanks were in use from approximately 1968 to 1975 and were removed in 2012. Low concentrations of explosives constituents were detected in groundwater during investigation of SWMU 28, which were determined to be related to SWMU 25. Therefore, No Further Action (NFA) was approved for SWMU 28, and the Resource Conservation and Recovery Act (RCRA) Permit (permit number SC8 170 022 620; South Carolina Bureau of Land and Waste Management, 2019) was updated accordingly, with further investigation of groundwater conducted as part of the investigation of

SWMU 25.

The former SWMU 29, South Annex Building 3820, is also partially located within the footprint of SWMU 25. SWMU 29 was a railcar cleaning area with low-level polycyclic aromatic hydrocarbon (PAH) impacts to soil and groundwater. Groundwater monitoring was performed at SWMU 29 in conjunction with the groundwater monitoring activities at SWMU 25. NFA was approved for SWMU 29 in 2017, and the RCRA Permit was updated accordingly.

Previous Studies

An Initial Assessment Study included a records search and onsite survey of SWMU 25 (Harmon Engineering and Testing, 1984). The Initial Assessment Study reported that munitions disposal at SWMU 25 took place from approximately 1918 to 1945. In 1965, efforts were made to clean up the site, and approximately 150 tons of munitions and explosives of concern (MEC) were removed, including grenades and 75 millimeter (mm), 81mm, and 105mm rounds. The 1965

Joint Base Charleston Weapons, South Carolina

Contract FA8903-15-C-0016 2 BWJ140078 removal occurred in the shoreline area, later identified as Burial Area 2 (Figure 2). Additional investigation in the 1980s indicated the potential presence of munitions constituents (MC;

Environmental Science and Engineering, Inc., 1987) and the RCRA Facility Assessment recommended further investigation to determine the nature and extent of contamination (Kearney/Centaur, 1988).

2003-2004, 2007 RCRA Facility Investigation – Surface water and sediment sampling and a geophysical survey were conducted as part of Phase I RCRA Facility Investigation (RFI) activities at SWMU 25. Semi-volatile organic compounds and metals were detected at concentrations exceeding screening criteria; however, no unacceptable risks were identified for human health or ecological receptors. The geophysical survey covered accessible areas surrounding Burial Area 1 and the Unexploded Area. A 70mm projectile was encountered on the surface in the northeastern portion of the parking lot and is believed to have been deposited during a construction effort. The report did not note the make or model of the 70mm projectile, the condition of the item, whether it contained explosives, or whether it was fuzed. No evidence of MEC was found in the survey of the Unexploded Area, but some areas were inaccessible (Tetra Tech, 2008).

SWMU 28 was also investigated during the RFI. Analytes were detected in groundwater at low concentrations, including the explosives constituents 1,3,5-trinitrobenzene, 2,4,6-trinitrotoluene, and 4-nitrotoluene (Tetra Tech, 2008). The explosives constituents in groundwater were attributed to SWMU 25. The USTs were removed in 2012, and NFA was granted for SWMU 28, with additional groundwater monitoring to be completed during the continuing investigation of SWMU

25. Note that the required groundwater monitoring was completed as part of the 2017 RI field activities (discussed below).

2009 Site Inspection – Further investigation of MEC and MC sampling were conducted during the Site Inspection in 2009. Investigation for MEC included an unexploded ordinance (UXO) detector-aided surface survey and geophysical survey on the landward side of Burial Area 2, a geophysical survey of the Water Range, and a UXO detector-aided surface survey within the Unexploded Area. No MEC was found on the surface in Burial Area 2, while four munitions debris (MD) items determined to be Vietnam-era were found (Figure 2), including plastic mortar shipping containers and a plastic end cap for a flare. The geophysical survey identified potential MEC disposal areas within Burial Area 2 and the Water Range. No MEC or MD was observed in the unexploded area. The MC investigation included soil, groundwater, surface water, and sediment sampling. No explosives constituents or propellants were detected in any of the samples. Metals were detected in all samples, with some results exceeding project action levels (PALs) in each medium (Tetra Tech, 2010).

2013 Engineering Evaluation/Cost Analysis – The Engineering Evaluation/Cost Analysis (EE/CA) evaluated removal action alternatives for MMRP sites, including SWMU 25 (URS, 2013).

The EE/CA selected MEC removal from surface and subsurface soil within Burial Areas 1 and 2.

2014 Remedial Investigation and Interim Removal Action – In 2014, RI and Interim Removal Action (IRA) activities were conducted including the following activities:

• Visual survey, surface clearance, digital geophysical mapping (DGM), and subsurface investigation of target anomalies within the Unexploded Area portion of SWMU 25.

• Diving operations to conduct underwater visual survey, an investigation of previously collected DGM target anomalies, and sediment sampling within the Water Range (i.e., the portion of SWMU 25 located within Goose Creek).

• Intrusive investigation (i.e., excavation) of previously collected DGM target anomalies throughout the remaining portions of SWMU 25 (i.e., Burial Area 1 and Burial Area 2).

Joint Base Charleston Weapons, South Carolina

Contract FA8903-15-C-0016 3 BWJ140078

• IRA at Burial Areas 1 and 2.

• Magnetometer-aided delineation of the two buried portions of fuze masses remaining in the subsurface of Burial Area 2.

• Visual survey of the unnamed portions of SWMU 25 located outside of the Unexploded Area, the Water Range, Burial Area 1, and Burial Area 2.

• MC sampling of sediment within the Water Range.

MEC including scattered Mk I PD fuzes and exposed portions of two large masses of buried, rusted, and overgrown fuze piles, which were identified during the visual survey and surface clearance in Burial Area 2 (Figure 2). No munitions-related features were observed in the Unexploded Area and the portion of SWMU 25 located between the SDDC Parking Lot and Burial Area 2. Surface-exposed portions of two buried fuze masses were identified and were removed by manual excavation at Burial Area 2. The fuze masses exposed at the surface were removed to an approximate depth of 1 foot below ground surface (bgs). A total of 280 fuzes were removed from one of the surface-exposed fuze masses, and 397 fuzes were removed from the second surface-exposed fuze mass. Further excavation of the fuzes within Burial Area 2 was impractical and risked damaging the shoreline/wetland environment. Therefore, the remaining buried portions of the two fuze masses were left in place, and the subsurface extents were estimated using magnetometers. In addition, five Mk I PD fuzes were recovered during RI diving operations within the Water Range area (URS, 2014, 2015, 2016).

The subsurface investigation of target anomalies confirmed that most areas within Burial Area 1 and Burial Area 2 contain no evidence of subsurface munitions. However, intrusive trenching activities at one location within Burial Area 1 confirmed the presence of MEC (Figure 2). A total of 103 Mk I PD fuzes were safely removed from the trench (at approximately 4 to 6 feet bgs in depth) before it began filling with water and further removal activities within the trench were deemed no longer safe to conduct (URS, 2014, 2015).

2017 Remedial Investigation – Additional RI field work was conducted in 2017. The TC Dock Finger Pier was identified and added to SWMU 25 in October 2011; investigation of this area was not included in the scope of previous investigations. Investigation of the TC Dock Finger Pier Area (both land and water portions) was completed in 2017. In addition, further investigation of the nature and extent of MC was conducted to complete the RI for SWMU 25. The investigation included installation and sampling of four monitoring wells (MWs). One MW was installed at the former SWMU 28, where explosives constituents were previously detected in groundwater, and three MWs were installed surrounding the Mk I PD fuze burial pit in Burial Area 1. Surface soil and sediment samples were collected in Burial Area 2 for further evaluation of metals previously detected in the area, and to investigate areas where MEC or MD were found. Additional surface soil and sediment samples were collected from locations where MD was found during investigation of the TC Dock Finger Pier Area. Groundwater, surface soil, and sediment samples were analyzed for explosives constituents and select metals (antimony, cadmium, chromium, copper, lead, and zinc; Bay West, 2018).

Investigation of the land portion (approximately 0.8 acre) included a visual survey, surface clearance, and analog survey with 100 percent intrusive investigation of anomalies. The water portion of the investigation area was approximately 1.3 acres. The MEC investigation of the water portion was conducted by traversing a linear search pattern using geographic positioning system (GPS) tracking to ensure complete coverage. The divers used an underwater metal detector to locate geophysical anomalies. Once detected, anomalies were investigated to a depth of up to 12 inches below the river bottom. No MEC was found in the TC Dock Finger Pier Area. Eleven 75mm projectiles and a munitions shipping container, all classified as MD, were found in the land portion

Joint Base Charleston Weapons, South Carolina

Contract FA8903-15-C-0016 4 BWJ140078 of the TC Dock Finger Pier Area. Three additional 75mm projectiles (empty and unfuzed MD) were found in the water portion of the TC Dock Finger Pier Area (Bay West, 2018).

Explosives constituents were not detected in any of the RI samples (groundwater, surface soil, or sediment). Metals detected in groundwater did not exceed PALs. Metals in surface soil and sediment did not exceed PALs for residential land use; however, some detections of antimony and zinc in sediment and copper and lead in both surface soil and sediment exceeded ecological screening values. MC results were evaluated in the human health risk assessment (HHRA) and ecological risk assessment (ERA), which concluded there were no unacceptable risks associated with MC at SWMU 25 (Bay West, 2018).

As part of the RI, a MEC Hazard Assessment was completed for each MRS. Based on the site information, particularly the type of MEC found (i.e., fuzes only) and the location of MEC (subsurface only), both MRSs associated with SWMU 25 (XE005 and XE005A) were assigned a Hazard Level of 4, or a low explosive hazard (Bay West, 2018).

Land Use Controls

As presented in the SWMU 25 Statement of Basis (Air Force, 2020), land use controls (LUCs) were selected as the remedy for SWMU 25 to address potential future human exposure to MEC remaining in the subsurface at Burial Areas 1 and 2 at SWMU 25. The LUCs for SWMU 25 include the following:

• The SWMU 25 LUC boundaries (inclusive of all polygon coordinates) will be logged into the Base geographic information system (GIS) to officially identify the site as being subject to a use restriction and to prompt Remedial Project Manager (RPM) reviews of any proposed disturbance or new use of the site. The LUCs at SWMU 25 will also be documented in the Installation Development Plan (IDP), which references the Base GIS.

• The RPM will review any project plans that may disturb SWMU 25. This review will take place prior to any construction or maintenance activity. This review is initiated when the Civil Engineer Squadron processes a dig permit for the site, for which the RPM is one of the required approvers. The RPM will also review plans for projects located at the site to determine if additional protections are needed for construction workers or the surrounding environment. The development and implementation of a health and safety program may be required for activities taking place at a site. If activities result in a change in land use at SWMU 25, the RPM will notify South Carolina Department of Health and Environmental Control (SCDHEC) as specified in the RCRA Permit.

• UXO construction support will be required, as necessary, for future construction activities or other intrusive work completed within the SWMU 25 MRSs. Any future intrusive activities at SWMU 25 would require an Explosives Safety Submission (ESS).

• Warning signs will be installed to notify site receptors of the potential subsurface MEC risks remaining at SWMU 25. Signs would be installed/maintained at access roads and around the site perimeter on land, as needed. Figure 3 presents the proposed warning sign locations and LUC boundary. Base security measures are currently implemented for the Water Range portion of SWMU 25 and limit waterway usage for transient purposes only (prohibiting recreational use); these security measures will be maintained.

• The soil cover over the buried MEC at SWMU 25 will be maintained. If the soil cover over the buried MEC is compromised (e.g., by erosion), it will be restored.

• Annual LUC inspections will be performed to confirm compliance with the LUCs (i.e., no unreported change in land use or construction activities, and to evaluate integrity of warning signs and soil cover). The annual inspection shall include an administrative review and visual observation of SWMU 25 to the extent that it is visible on land.

Joint Base Charleston Weapons, South Carolina

Contract FA8903-15-C-0016 5 BWJ140078

2.0 SUMMARY OF PROJECT TASKS

The LUC monitoring program is being implemented in accordance with Appendix D of the RCRA Permit. Annual inspections will be conducted to ensure that the LUCs remain in effect at the site.

The LUCs boundary and the proposed warning sign locations are presented on Figure 3. The LUCs ensure that proper planning, permissions, and safety considerations will be implemented prior to future construction activities or change in land use on the site. In support of this, the following field activities/schedule will be conducted:

Task Frequency Anticipated

Month Information Reported to

Regulators

Documentation of LUC boundary in the Base GIS with reference in the IDP and review of proposed activities within the LUC boundary through the Base dig permit process.

Ongoing Ongoing Report change in land use, if any.

Utilize UXO construction support for future construction activities or other intrusive work completed within SWMU 25, as necessary. Prepare an ESS for any future intrusive activities at SWMU 25.

Ongoing Ongoing Not applicable

Install warning signs as indicated on Figure 3 to notify site receptors of the potential subsurface MEC risks remaining at SWMU 25. Signs will be installed/maintained at access roads and around the site perimeter on land, as needed.

Once To be determined Notification of completion of warning sign installation

Maintain the soil cover over the buried MEC at SWMU 25. If the soil cover over the buried MEC is compromised (e.g., by erosion), it will be restored.

Ongoing Ongoing Not applicable

LUC Monitoring Annual April/May Within 90 days of inspection

2.1 Land Use Control Inspections

LUC inspections will be conducted annually. The annual inspection shall include an administrative review and visual observation of SWMU 25 to the extent that it is visible on land. The visual inspection will assess the condition of the warning signs and soil cover over areas of buried MEC at SWMU 25. The LUC inspections will be documented using the site-specific LUC checklist (Attachment 1). The completed checklist will include a photographic log of the site visit.

2.2 Annual Reporting

The completed LUC checklist will be submitted annually within 90 days of the inspection. The annual report will document the LUC inspections along with any deficiencies and measures taken to correct deficiencies.

Joint Base Charleston Weapons, South Carolina

Contract FA8903-15-C-0016 6 BWJ140078

3.0 REFERENCES

Air Force, 2020. Statement of Basis for Land Use Controls, Solid Waste Management Unit 25 (XE005), Old South Annex Munitions Disposal Area, Joint Base Charleston Weapons, South Carolina.

Bay West, 2018. Final Remedial Investigation Report, Solid Waste Management Unit 25/UXO 5 (XE005), Performance-Based Remediation, Joint Base Charleston Weapons, South Carolina. September.

Environmental Science and Engineering, Inc., 1987. Confirmation Study, Characterization Step, Naval Weapons Station, Charleston, South Carolina. Tampa, Florida, August.

Harmon Engineering and Testing, 1984. Initial Assessment Study of Naval Weapons Station, Charleston, South Carolina. NEESA 13-040, Auburn, AL, January.

Kearney/Centaur, 1988. Interim RCRA Facility Assessment Report, Naval Weapons Station Charleston, South Carolina. Kearney/Centaur, a division of A.T. Kearney, Inc., Alexandria, VA, May.

South Carolina Bureau of Land and Waste Management, 2019. Resource Conservation and Recovery Act (RCRA) Part B Permit Number SC8 170 022 620, effective 22 September 2011 through 22 September 2021. Modified 23 October 2019.

Tetra Tech, 2008. Phase I and II RFI Report SWMUs 25, 28, 29 and 40 – Confirmatory Sampling Report SMU 71 and AOC H. Naval Weapons Station Charleston, South Carolina.

September.

Tetra Tech, 2010. Site Inspection Report for Munitions Response Program Sites SWMU 20, SWMU 22, SWMU 25, SWMU 79, AOC L, and AOC N Weapons Station Charleston, Charleston, South Carolina. (Revision 1). September.

URS Group, Inc., 2013. Engineering Evaluation/Cost Analysis, SWMU 20, SWMU 25 (Burial Areas 1 and 2), SWMU 79, SWMU 81, SWMU 82, AOC L, and AOC N. Final. May.

URS Group, Inc., 2014. Abbreviated Interim Removal Action Summary Document for SWMU 25 MRS. Military Munitions Response Program, Joint Base Charleston – Weapons, South Carolina. Draft Final. September.

URS Group, Inc., 2015. Interim Removal Action Site Specific Final Report, SWMU 20, SWMU 25 (Burial Areas 1 and 2), SWMU 79, SWMU 81, SWMU 82, AOC L, and AOC N. Military Munitions Response Program, Joint Base Charleston – Weapons, South Carolina. Final.

April.

URS Group, Inc., 2016. Final Remedial Investigation/Feasibility Study, SWMU 20, SWMU 22, SWMU 79, SWMU 81, SWMU 82, AOC L, and AOC N. Military Munitions Response Program, Joint Base Charleston – Weapons, South Carolina. August.

Joint Base Charleston Weapons, South Carolina

Contract FA8903-15-C-0016 BWJ140078

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Figure 1 SWMU 25 Site Location Map

Drawn By: Project No.

µJoint Base Charleston

SOUTH CAROLINA

CEN J140078Date Drawn/Revised: 12/17/2020

Joint Base Charleston Weapons Charleston, South Carolina

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LUC Boundary and Proposed Warning Sign Locations

Joint Base Charleston Weapons Charleston, South Carolina

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Joint Base Charleston Weapons, South Carolina

Contract FA8903-15-C-0016 BWJ140078

Attachment 1: LUC Checklist

Inspection Checklist (Working document for site inspection. Information may be completed by hand and attached to the Inspection report as supporting documentation of site status. “N/A” refers to “not applicable.”)

Highlighted items must be filled out/updated during inspection

I. SITE INFORMATION

Site Name: SWMU 25 (XE005) Date of Inspection: MM/DD/YYYY

County and State: Berkeley County, SC EPA ID: SC8 170 022 620

Agency, office, or company conducting the inspection: Bay West LLC Weather/Temperature: XXXXX

Description of LUC:

• Restriction of future construction activities or changes in land use unless proper planning, permissions, and safety considerations are made.

• Documentation of LUC boundaries in the Base geographic information system and review of proposed activities within the LUC boundaries through the Base dig permit process.

• Install warning signs to notify site receptors of the potential subsurface MEC risks remaining at SWMU 25. Signs will be installed/maintained at access roads and around the site perimeter on land, as needed.

• Maintain the soil cover over the buried MEC at SWMU 25. If the soil cover over the buried MEC is compromised (e.g., by erosion), it will be restored.

• Complete annual LUC inspections using the SWMU 25 LUC Monitoring Checklist.

II. ACCESS AND INSTITUTIONAL CONTROLS: Applicable N/A

A. Fencing

1. Fencing Damaged Location shown on site map Gates secured N/A

Fencing is not a required element of the SWMU 25 LUCs.

B. Other Access Restrictions

1. Signs and other security measures Location shown on site map N/A

C. Institutional Controls (ICs)

1. Implementation and enforcement Site conditions imply LUCs not properly implemented Yes No N/A

Site conditions imply LUCS not being fully enforced Yes No N/A

Type of monitoring (e.g., self-reporting, drive by): Visual observation of site

Frequency: Annual

Responsible party/agency: Joint Base Charleston Weapons

Inspection Completed By: XXXX XXXX (###) ###-#### Name Title Phone #

Reporting is up-to-date Yes No N/A

Specific requirements in deed or decision documents met Yes No N/A

Violations have been reported Yes No N/A

Other problems or suggestions:

1. Adequacy ICs are adequate ICs are inadequate N/A

Remarks:

D. General

1. Vandalism/trespassing Location on site map No vandalism evident

Remarks: ______________________________________________________________________

2. Land use changes on site Yes No N/A Remarks:

III. GENERAL SITE CONDITIONS

A. Roads Applicable N/A

1. Roads damaged Location shown on site map Roads adequate N/A

Remarks:

2. Evaluation of Existing Soil Cover

Remarks:

IV. OVERALL OBSERVATIONS

A. Implementation of the Remedy Describe issues and observations relating to the whether the remedy is effective and functioning as designed. Begin with a brief statement of what the remedy is to accomplish (i.e., maintain existing soil cover, minimize infiltration and gas emission, etc.)

B. Early Indicators of Potential Remedy Problems Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of unexpected repairs to the existing soil cover that suggest that the protectiveness of the remedy may be compromised in the future.

SWMU 25 (XE005) LUC Inspection Photo Log MM/DD/YYYY

Photo Number:

Photo 1 here

Description:

XXXX

Photo Number:

Photo 2 here (continue photo log as needed on additional pages)

Description:

XXXX

Attachment 1: LUC Checklist