Final_Scope_of_Work_-_RFP_rev02.pdf

Final Scope of Work Remediation of Soils Operable Unit Luckey Site Luckey, Ohio

May 2014 Formerly Utilized Sites Remedial Action Program

Scope of Work i

Table of Contents

ACRONYMS AND ABBREVIATIONS ...........................................................................................vi

1 GENERAL .............................................................................................................. 1-1

1.1 Contract Award ......................................................................................................................... 1-1

1.2 Scope of Work .......................................................................................................................... 1-1

2 REGULATORY BACKGROUND .................................................................................... 2-1

2.1 Regulatory Compliance ............................................................................................................. 2-1

2.2 Administrative Record .............................................................................................................. 2-1

2.3 Stakeholders ............................................................................................................................. 2-1

3 BACKGROUND ....................................................................................................... 3-1

3.1 Site Location and Description ................................................................................................... 3-1

3.2 Previous Site Operations, Structures, Material Handling and Disposal Activities .................... 3-1

3.2.1 Previous Site Operations .................................................................................................. 3-1

3.2.2 Buildings and Ancillary Structures ................................................................................... 3-2

3.2.3 Material Handling and Disposal Activities ....................................................................... 3-3

3.3 Previous Investigations ............................................................................................................. 3-3

4 SITE CONDITIONS ................................................................................................... 4-1

4.1 Topography and Drainage ........................................................................................................ 4-1

4.2 Geology and Hydrogeology ...................................................................................................... 4-1

4.2.1 Geology ............................................................................................................................ 4-1

4.2.2 Hydrogeology ................................................................................................................... 4-2

4.3 Constituents of Concern ........................................................................................................... 4-2

4.3.1 Clean-up Goals ................................................................................................................. 4-2

4.3.2 Contaminated Areas / Media ........................................................................................... 4-3

4.3.3 Organic Contaminants ..................................................................................................... 4-7

5 REMEDIATION ACTIVITIES AND REQUIREMENTS ........................................................... 5-1

5.1 Mobilization and Preparatory Work - 331XX01 ....................................................................... 5-2

5.1.1 Mobilization of Construction Equipment and Facilities - 331XX0101 ............................. 5-2

5.1.2 Submittals / Implementation Plans - 331XX0103 ............................................................ 5-3

5.1.3 Meetings ........................................................................................................................ 5-15

5.1.4 Setup / Construct Temporary Facilities - 331XX0104 .................................................... 5-15

5.2 Monitoring, Sampling, Testing, and Analysis - 331XX02 ........................................................ 5-16

5.2.1 Meteorological Monitoring - 331XX0201 ...................................................................... 5-16

5.2.2 Radiation Monitoring - 331XX0202 ............................................................................... 5-16

5.2.3 Air Monitoring and Sampling - 331XX0203 .................................................................... 5-17

5.2.4 Monitoring Wells - 331XX0204 ...................................................................................... 5-17

5.2.5 Sampling Surface Water / Groundwater / Liquid Waste - 331XX0205 .......................... 5-17

5.2.6 Sampling Soil and Sediment - 331XX0206 ..................................................................... 5-18

5.2.7 Sampling Radioactive Contaminated Media - 331XX0208 ............................................ 5-18

5.2.8 Laboratory Chemical Analysis - 331XX0209 ................................................................... 5-18 ii

5.2.9 Radioactive Waste Analysis - 331XX0210 ...................................................................... 5-19

5.2.10 Geotechnical Testing - 331XX0211 ................................................................................ 5-19

5.2.11 On-Site Laboratory Facilities - 331XX0213 ..................................................................... 5-19

5.2.12 Beryllium Monitoring, Sampling, Testing, and Analysis - 331XX0290 ........................... 5-19

5.3 Site Work - 331XX03 ............................................................................................................... 5-19

5.3.1 Clearing and Grubbing - 331XX0302 .............................................................................. 5-19

5.3.2 Roads / Parking / Curbs / Walks - 331XX0304 ............................................................... 5-20

5.3.3 Fencing - 331XX0305 ...................................................................................................... 5-20

5.4 Surface Water Collection and Control - 331XX05 ................................................................... 5-20

5.5 Solids Collection and Containment - 331XX08 ....................................................................... 5-20

5.6 Liquids / Sediments / Sludges Collection and Containment - 331XX09 ................................. 5-20

5.7 Drums / Tanks / Structures / Miscellaneous Demolition and Removal - 331XX10 ................ 5-21

5.8 Disposal (Commercial) - 331XX19 ........................................................................................... 5-21

5.9 Site Restoration - 331XX20 ..................................................................................................... 5-21

5.10 Demobilization - 331XX21 ...................................................................................................... 5-22

5.10.1 Submittals - 331XX2106 ................................................................................................. 5-22

5.11 General Requirements - 331XX22 .......................................................................................... 5-24

5.11.1 Supervision and Management - 331XX2201 .................................................................. 5-24

5.11.2 Engineering, Surveying, and Quality Control - 331XX2204 ............................................ 5-25

5.11.3 First Aid, Fire Protection, and Traffic Control - 331XX2206 ........................................... 5-25

5.11.4 Health & and Safety - 331XX2207 .................................................................................. 5-25

5.11.5 Temporary Construction Facilities – Ownership - 331XX2208 ...................................... 5-26

5.11.6 Temporary Construction Facilities – Operation - 331XX2209 ....................................... 5-26

5.11.7 Project Utilities - 331XX2210 ......................................................................................... 5-26

6 CONTRACTOR PROJECT STAFF ORGANIZATION, QUALIFICATIONS AND RESPONSIBILITIES ...... 6-1

6.1 List of Key Individuals, Qualifications and Responsibilities ...................................................... 6-1

6.1.1 Program Manager ............................................................................................................ 6-1

6.1.2 Project Manager .............................................................................................................. 6-2

6.1.3 Site Superintendent ......................................................................................................... 6-3

6.1.4 Safety and Health Manager ............................................................................................. 6-3

6.1.5 Site Safety and Health Officer (SSHO) .............................................................................. 6-4

6.1.6 Radiation Safety Officer ................................................................................................... 6-5

6.1.7 Construction Quality Control System Manager ............................................................... 6-5

6.1.8 Waste Manager ................................................................................................................ 6-6

6.1.9 Project Chemist ................................................................................................................ 6-7

6.2 Other Contractor Site Personnel .............................................................................................. 6-7

6.3 CONTRACTOR Corporate Support Staff .................................................................................... 6-8

6.3.1 Civil Engineer ................................................................................................................... 6-8

6.3.2 Hydrogeologist ................................................................................................................. 6-8

6.3.3 Cost Scheduler ................................................................................................................. 6-9

6.3.4 Contracts Manager .......................................................................................................... 6-9

6.4 Other Personnel........................................................................................................................ 6-9

7 RESIDENT MANAGEMENT SYSTEM ............................................................................. 7-1

8 Deliverables and Submittals ..................................................................................... 8-1 iii

8.1 General Requirements .............................................................................................................. 8-1

8.2 Independent Technical Review ................................................................................................ 8-2

8.3 Data .......................................................................................................................................... 8-2

8.4 CONTRACTOR Submittal Procedures ........................................................................................ 8-3

9 GREEN AND SUSTAINABLE REMEDIATION AND INNOVATIVE TECHNOLOGIES ...................... 9-1

10 GOVERNMENT FURNISHED PROPERTY ...................................................................... 10-1

11 PUBLIC AFFAIRS ................................................................................................... 11-1

12 REAL ESTATE RIGHTS ............................................................................................. 12-1

13 INVOICES ............................................................................................................ 13-1

14 REFERENCES ........................................................................................................ 14-1

APPENDICES

Appendix A - Figures

Figure 1 - Site Location Figure 2 - Site Vicinity Figure 3 - Site Features Figure 4 - Modeled Lateral Extent of FUSRAP-Contaminated Soils/Fill/Debris Figure 5 - Modeled Depth of FUSRAP- Contaminated Soils/Fill/Debris

Appendix B - Unified Guide Specifications (UFGS) and Corps of Engineers Buffalo District (CELRB) Technical Requirements

CELRB Air Monitoring Requirements CELRB Analytical Laboratory Requirements and Data Deliverables CELRB Beryllium Exposure Standard Variance Letter CELRB Chronic Beryllium Disease Prevention Program, Beryllium Hazard Analysis, and Beryllium Work Permit Outlines UFGS Section 01 22 00.00 10 MEASUREMENT AND PAYMENT UFGS Section 01 32 01.00 10 PROJECT SCHEDULE UFGS Section 01 32 16.00 20 CONSTRUCTION PROGRESS DOCUMENTATION UFGS Section 01 33 00 SUBMITTAL PROCEDURES UFGS Section 01 35 26 GOVERNMENTAL SAFETY REQUIREMENTS UFGS Section 01 35 29.13 HEALTH SAFETY & EMERGENCY RESPONSE PROCEDURES FOR

CONTAMINATED SITES

UFGS Section 01 35 45.00.10 CHEMICAL DATA QUALITY CONTROL UFGS Section 01 45 00.00 10 QUALITY CONTROL UFGS Section 01 50 00 TEMPORARY CONSTRUCTION FACILITIES AND CONTROLS UFGS Section 01 57 23 TEMPORARY STORM WATER POLLUTION CONTROL UFGS Section 01 58 00 PROJECT IDENTIFICATION iv

UFGS Section 02 41 00 DEMOLITION UFGS Section 02 61 13 EXCAVATION AND HANDLING OF CONTAMINATED MATERIAL UFGS Section 02 81 00 TRANSPORTATION AND DISPOSAL OF HAZARDOUS MATERIALS UFGS Section 02 82 16.00 20 ENGINEERING CONTROL OF ASBESTOS HAZARD CONTROL ACTIVITIES UFGS Section 31 11 00 CLEARING AND GRUBBING

ATTACHMENTS

Attachment 1 Background Figures and Drawings

1.1 USGS Quadrangles

1.2 Site Contour Maps

1.3 Historic Facility Drawings (Bechtel)

1.4 Site Plan (Uretech)

1.5 Building Layouts (Uretech)

1.6 Misc Facility Drawings (Ohio Environmental Protection Agency)

1.7 Building Photos (USACE - 23JUL10)

Attachment 2 Select Remedial Investigation (RI) and Volume Uncertainty Investigation (VUI) Tables, Figures, and Appendices

2.1 RI Site Background Tables

2.2 RI Site Background Figures

2.3 RI Activities Figures

2.4 RI Nature & Extent Tables

2.5 RI Results Figures

2.6 RI Fate & Transport Tables

2.7 RI Boring & Monitoring Well Logs

2.8 VUI Methods Tables

2.9 VUI Methods Figures

2.10 VUI Results Tables

2.11 VUI Results Figures

2.12 VUI Geophysical Survey Tables

2.13 VUI Geophysical Survey Figures

2.14 VUI Photo Log

2.15 VUI Boring Logs

2.16 VUI Monitoring Well Logs

2.17 VUI Trench Logs

2.18 Current Well Construction Summary

Attachment 3 Volume Estimate Summary

Attachment 4 Hazardous, Toxic and Radioactive Waste Remedial Action Work Breakdown Structure and Data Dictionary

Attachment 5 USACE Safety Forms v

5.1 CELRB Accident Prevention Plan/Site Safety and Health Plan (APP/SSHP) Checklist

5.2 Activity Hazard Analysis Template

5.3 Monthly Man-Hour Report Template

5.4 Engineering Form 3394 Accident Investigation Report

5.5 Crane Certificate of Compliance

5.6 Hot Work Permit Blank Form

Attachment 6 Environmental Restoration Program Information Management System (ERPIMS) Data Format Dictionary

Attachment 7 Submittal Forms

7.1 ENG Form 4025

7.2 ENG Form 4288

Attachment 8 Decision Framework for Incorporation of Green and Sustainable Practices into Environmental Remediation Projects

Attachment 9 Progress Payment Checklist vi

ACRONYMS AND ABBREVIATIONS

ACGIH American Conference of Governmental Industrial Hygienists ACM asbestos-containing material AE Architect - Engineer AEC (U.S.) Atomic Energy Commission AGC (U.S.) Army Geospatial Center AHA Activity Hazard Analysis amsl above mean sea level ANSI American National Standards Institute APP Accident Prevention Plan ARSO Assistant Radiation Safety Officer ASTM American Society of Testing and Materials BARP Backfill and Restoration Plan BBC Brush Beryllium Company BeLPT Beryllium Lymphocyte Proliferation Test bgs below ground surface BMP Best Management Practices BIHA Baseline Inventory and Hazard Assessment CADD computer aided design and drafting CBDPP Chronic Beryllium Disease Prevention Program CELRB Corps of Engineers Buffalo District CFR Code of Federal Regulations CHP Certified Health Physicist CIH Certified Industrial Hygienist CLIN Contract Line Item Number CM Construction Manager cm/sec centimeters per second COCs constituents of concern COI constituent of interest COR Contracting Officer’s Representative CPFF cost plus fixed-fee CQC CONTRACTOR’S Quality Control CRZ Contamination Reduction Zone CSP Certified Safety Professional D&D decontamination and decommissioning DFARS Defense Federal Acquisition Regulation Supplement DOD (U.S.) Department of Defense DOE (U.S.) Department of Energy DOT (U.S.) Department of Transportation vii

DQO data quality objective EM Engineer Manual ER Engineer Regulation ELAP Environmental Laboratory Accreditation Program Elev elevation EPCRA Emergency Preparedness Community Right-to-Know ERPIMS Environmental Restoration Program Information Management System EZ Exclusion Zone FFP firm-fixed price FSP Field Sampling Plan FSSP Final Status Survey Plan ft foot (feet) ft2 square feet ft/day feet per day FUSRAP Formerly Utilized Sites Remedial Action Program g gram gal/min gallons per minute GIS Geographic Information System GSR Green and Sustainable Remediation HLI Hayes Lemmerz International, Inc.

HP health physics HTRW hazardous, toxic and radioactive waste IAW in accordance with IDIQ Indefinite Delivery/Indefinite Quantity IH industrial hygiene IPR Industrial Properties Recovery, Inc.

ISO International Organization for Standardization IT Innovative Technologies ITR independent technical review KO Contracting Officer LIBS laser-induced breakdown spectroscopy MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual MED Manhattan Engineer District mg/kg milligrams per kilogram mg/m3 milligrams per cubic meter MIS Management Information System mrem/yr millirems per year NAD North American Datum NAVD North American Vertical Datum of 1988 NCP National Oil and Hazardous Substances Pollution Contingency Plan viii

NPDES National Pollutant Discharge Elimination System NRC (U.S.) Nuclear Regulatory Commission ODNR Ohio Department of Natural Resources ODH Ohio Department of Health OACSIM Office of the Assistant Secretary for Installation Management Ohio EPA Ohio Environmental Protection Agency OEW Ordnance Explosive Waste O&M operation and maintenance ORNL Oak Ridge National Laboratory OSH Occupational Safety and Health OSHA Occupational Safety and Health Administration PAMP perimeter air monitoring plan PCBs polychlorinated biphenyls pCi picocurie pCi/g picocuries per gram pdf portable document format PM10 particulate matter < 10 µm PPE personal protective equipment ppm parts per million QA quality assurance QAPP Quality Assurance Project Plan QC quality control QCS Quality Control System Ra Radium Ra226 Radium 226 RCP Regulatory Compliance Plan RCRA Resource Conservation and Recovery Act RI remedial investigation RMS Resident Management System ROD Record of Decision RPP Radiation Protection Plan RSO Radiation Safety Officer SAP Sampling and Analysis Plan SATOC Single Award Task Order Contract SDSFIE Spatial Data Standard for Facilities, Infrastructure and Environment sec second SHM Safety and Health Manager SOR sum of the ratios SOP Site Operations Plan SOW Scope of Work ix

SPCC Spill Prevention, Control, and Countermeasures SSHO Site Safety and Health Officer SSHP Site Safety and Health Plan SVOCs semi-volatile organic compounds SWPPP Storm Water Pollution Prevention Plan SZ Support Zone Th Thorium Th230 Thorium 230 toc top of casing TRPH total recoverable petroleum hydrocarbons U Uranium U234 Uranium 234 U238 Uranium 238 Utotal total uranium UFGS Unified Facilities Guide Specification USACE United States Army Corps of Engineers USDOL United States Department of Labor USEPA United States Environmental Protection Agency USGS United States Geological Survey VOCs volatile organic compounds VUI volume uncertainty investigation WBS work breakdown structure WMTDP Waste Management, Transportation, and Disposal Plan WMP Water Management Plan WWPPP Waste Water Pollution Prevention Plan yr year µg/m3 micrograms per cubic meter

1-1

1 GENERAL

1.1 Contract Award

The United States Army Corps of Engineers (USACE) intends to award a ten-year indefinite delivery/indefinite quantity (IDIQ) single award task order contract (SATOC), to include for remediation of the Formerly Utilized Sites Remedial Action Program (FUSRAP) Luckey Soils Remediation Project in Luckey, Wood County, Ohio. The contract will include a five-year base period and one five-year option period in accordance with (IAW) DFARS 217.204. The IDIQ will include a mix of firm-fixed price (FFP) and cost plus fixed fee (CPFF) task orders. The contract will be procured as a set aside for small business.

1.2 Scope of Work

Environmental remediation services are required in this Scope of Work (SOW) for FUSRAP-contaminated soils / fill and debris at the Luckey Site in accordance with the Record of Decision (ROD) for the Soils Operable Unit (USACE, 2006). The CONTRACTOR shall furnish all labor, materials, equipment, and supervision to perform the remedial activities required under this SOW that may include, but are not limited to, the development of work plans, development and implementation of site closure protocols, environmental monitoring, building demolition, excavation, waste characterization, waste packaging, and transport and disposal of materials contaminated with FUSRAP-related constituents of concern (COCs) which include beryllium (Be), lead (Pb), radium-226 (Ra226), thorium-230 (Th230), uranium-234 (U234) and uranium-238 (U238). Additional activities may include, but are not limited to: water handling/management, environmental investigation, design, construction and/or modification of site infrastructure, preparation of appropriate documents and work plans, site maintenance, site restoration, interaction with local state and state local agencies, emergency response agencies, assisting with preparation for and participation at public meetings, and any other actions necessary to remediate the Luckey Site

The waste types anticipated at the Luckey include, but are not limited to:

• Beryllium contaminated waste;

• Low-activity radioactive waste (LARW);

• Low-activity radioactive waste (LARW) contaminated with Be;

• Hazardous waste subject to the Resource Conservation and Recovery Act (RCRA);

• Hazardous waste subject to RCRA contaminated with Be;

• Mixed waste (i.e., waste that contains both LARW and Hazardous Waste subject to RCRA); and

• Mixed waste contaminated with Be.

Based on the SOW, the CONTRACTOR shall prove in their proposal that they are experts/specialists in the environmental field including remediation activities, specifically for the Luckey COCs. As such, it is expected that the CONTRACTOR shall be able to act as a consultant to provide guidance and make recommendations with minimal USACE direction as it relates to the work in the field, and foreseen/unforeseen conditions encountered which will improve the performance and/or reduce field

1-2 costs of the project while operating in a safe manner that is protective of human health and the environment.

2-1

2 REGULATORY BACKGROUND

The USACE is the lead agency for this remedial action and has overall responsibility for execution of the project subject to 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) 40 Code of Federal Regulations (CFR) 300.

2.1 Regulatory Compliance

The CONTRACTOR shall comply with all federal, state, and local regulations while performing work under this contract. The CONTRACTOR shall bear sole responsibility for any non-conformance resulting from the actions or directions of their employees or subcontractor employees.

2.2 Administrative Record

The Administrative Record file for the Luckey Site is located at the following locations:

U.S. Army Corps of Engineers, Buffalo District 1776 Niagara Street Buffalo, New York 14207

Luckey Public Library 228 Main Street Luckey, Ohio 43443

A subset of the Administrative Record is accessible on the Luckey public website:

http://www.lrb.usace.army.mil/Missions/HTRW/FUSRAP/LuckeySite.aspx

2.3 Stakeholders

Principal project stakeholders are listed below.

• Property Owner, Industrial Properties Recovery LLC (IPR)

• Ohio Environmental Protection Agency (Ohio EPA)

• Ohio Department of Natural Resources (ODNR)

• Ohio Department of Health (ODH)

• State of Ohio o Honorable John Kasich, Governor o Honorable Mark Wagoner, State Senate, 2nd District

• Wood County Commissioners

• Wood County Board of Health

• Township of Troy

• Honorable Belinda Brooks, Mayor, Village of Luckey, Ohio

• Federal Government o Honorable Randy Gardner, U.S. House of Representatives, 14th District o Honorable Sherrod Brown, U.S. Senate o Honorable Rob Portman, U.S. Senate http://www.lrb.usace.army.mil/Missions/HTRW/FUSRAP/LuckeySite.aspx

2-2

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

3-1

3 BACKGROUND

3.1 Site Location and Description

The Luckey Site is located at the corner of Gilbert and Luckey Roads at 21200 Luckey Road, northwest of the Village of Luckey in Wood County, Ohio. The village of Luckey is 22 miles southwest of Toledo, Ohio (Appendix A - Figures 1 and 2). The site encompasses approximately 40 acres and contains a large production building and warehouse, two abandoned rail spurs, and several smaller process and support buildings (Appendix A - Figure 3). The site is bordered by Luckey Road to the west, Gilbert Road to the south, abandoned railroad tracks to the east, and private farmland to the north. The surrounding area west, north, and east of the site is primarily residential farmland. The site was used for beryllium processing in support of the national defense program. Atomic Energy Commission (AEC)-related beryllium production activities and related operations occurred at the site from 1949 to 1961. Beryl ore (beryllium aluminum silicate); scrap beryllium; and radiologically contaminated scrap metal were brought to the site during this period.

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

3.2.1 Previous Site Operations

In 1942 a magnesium processing facility was built at the Luckey Site on U.S. Government land. The facility was operated for the U.S. Government by National Lead during World War II until 1945. In 1949, the AEC built a beryllium production facility at the site that was operated by Brush Beryllium Company (BBC), which later became Brush Wellman. The facility produced beryllium oxide, beryllium hydroxide, and beryllium pebbles that were shipped to other facilities for further processing. The Luckey Site facilities were owned by the AEC and operated by BBC from 1949 to 1958. During non-peak use of the facilities, BBC leased portions of the plant for commercial uses.

In late 1951 and early 1952, the AEC sent approximately 1,000 tons of radiologically contaminated scrap metal to the site in anticipation of resuming magnesium processing. The scrap metal, which contained radioactivity levels within guidelines at the time, was stored at the site and never used for its intended purpose. Records also indicate that beryllium scrap from other AEC operations was sent to the site that might have been radiologically contaminated. BBC operated the facility until 1958 when beryllium production ceased. Sintering and powder blending operations, established at the Luckey facility in 1957, continued until 1960.

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

3-2

In 1968 the Goodyear Tire and Rubber Company purchased the site and began producing automotive foam seating and other urethane products. In 1983 the Motor Wheel Company leased the property from Goodyear, later purchasing it in 1988. Motor Wheel used the site to coat steel automotive steering wheels with polyurethane foam and to manufacture other automotive products. Hayes Lemmerz International, Inc., (HLI) is the successor company to Motor Wheel. From 1995 to 2004 HLI leased about 23 acres of the site to Uretech International, Inc., which manufactured urethane parts for the automotive, sporting goods, and health care industries.

In 2006 Hayes Lemmerz sold the property to Industrial Properties Recovery LLC (IPR), an industrial scrapping business. Shortly after purchase, IPR began demolishing several ancillary buildings including the former Production Annex building (Appendix A - Figure 3). During December 2006, the Ohio Department of Health (ODH) issued an Emergency Adjudication Order to IPR, to cease demolition of buildings and handling of any radioactive material.

The Wood County Combined General Health District deemed the site a public health and safety concern and the Wood County Court issued an injunction against IPR during June 2009. The injunction requires IPR to either demolish or make necessary repairs to site structures and salvage or properly dispose of all debris, rubbish, and garbage. IPR resumed demolition and salvage activities during late 2013.

The site/facilities are not currently being used. However, the CONTRACTOR shall coordinate with USACE and the property owner to ensure that remedial activities do not conflict with any activities proposed by the property owner.

3.2.2 Buildings and Ancillary Structures

There are several large buildings and smaller structures at the site that were built to house or support magnesium production activities and subsequently used during beryllium processing and sintering activities (refer to Figure 3 located in Appendix A).

Large Buildings

• Production building

• Production annex

• Melting, alloying and shipping building

• Laboratory building

• Maintenance office building

• Main office

• Employee activity building

Small Structures

• Pump house (for fire protection water)

• East and west well houses

• Guard house

• Shack

3-3

• Sewage treatment plant

The large buildings were constructed with brick and concrete with some metal sheathing over steel supports. The building roofs are steel trusses that are generally triangular shaped. The small structures (guard shacks and pump houses) are a mix of concrete block, brick, and wood framing. Elevation, section, and miscellaneous details of the production building are provided in historical documents and facility drawings in Attachment 1. The production annex building has been demolished and only the building floor slab and demolition debris remain. As stated previously, the current site owner, IPR, resumed demolition and salvage activities during late 2013.

The sewage treatment plant consisted of a wet well and pump room, dosing chamber, aeration tank, settling tank, septic tank, and sand filters. Two abandoned railroad spurs and two water supply wells are also present on site.

3.2.3 Material Handling and Disposal Activities

Documented material handling and disposal areas at the site include:

• Lagoons that received beryllium processing sludges.

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

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

• A sewage treatment plant.

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

• Scrap metal storage areas.

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

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

The approximate locations of these areas are illustrated on Figure 3 (Appendix A).

3.3 Previous Investigations

Previous site investigations and evaluations are summarized below.

• Oak Ridge National Laboratory (ORNL1988) – preliminary radiological survey and sampling / analysis of soil and surface water samples.

• U.S. Department of Energy (DOE1996) – preliminary site evaluation of beryllium and radionuclide contamination detected during the ORNL survey.

• USACE 1998 – wetlands designation survey.

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

o Gamma walkover surveys;

o Laser-induced breakdown spectroscopy (LIBS) survey of soil for beryllium contamination;

o Geophysical surveys;

o Sampling and analysis of background soil, sediment, surface water and air;

o Sampling and analysis of off-site surface water, sediment, and groundwater;

3-4 o Sampling and analysis of site soil, sediment, surface water, groundwater; and o Sampling and analysis of building dust, structures and ambient air.

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

o Topographic survey;

o Geophysical surveys;

o Gamma walkover surveys;

o Investigative trenching, sampling and analysis of sediment and soil from underground utilities; and o Sampling and analysis of site soil and groundwater.

• Annual Groundwater Monitoring.

o 2009 Annual Groundwater Monitoring Data (USACE 2010).

o 2010 Annual Groundwater Monitoring Data (USACE 2011a.)

o 2011 Annual Groundwater Monitoring Data (USACE 2012).

o 2012 Annual Groundwater Monitoring Data (USACE 2013a).

o 2013 Annual Groundwater Monitoring Data (USACE 2013b).

4-1

4 SITE CONDITIONS

4.1 Topography and Drainage

Topography surrounding the Luckey Site is flat and consists of low surface gradients sloping toward Lake Erie at a rate of approximately 3 to 4 feet (ft) per mile. Surface elevations at the site and vicinity range from approximately 663 to 637 ft above mean sea level (amsl). The site is generally higher in areas where past disposal and material handling activities were conducted. These areas include the lagoons, dosing chamber, northeast corner of the site and debris piles east and southeast of the sewage treatment plant sand filters.

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

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

4.2 Geology and Hydrogeology

4.2.1 Geology

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

Boring logs from the RI and VUI are provided in Attachment 2.

4.2.1.1 Soils

The predominant soils in the area are clays of the Hoytville series, which are very poorly drained, dark-colored soils formed from fine-grained, gritty till on broad flats. Most native soils on the site consist of the Hoytville clay, while a section near the southeast corner contains the Hoytville clay loam (USACE, 2003). These soils are almost identical, except for slight variations in the clay content. Surface infiltration on Hoytville soils is poor. Most soils at the site are classified as lean clay with some fine sand and silt. Attachment 2 provides geotechnical data associated with samples collected during the RI and

VUI.

4-2

4.2.1.2 Bedrock

The Lockport Dolomite is the uppermost bedrock formation at the site and ranges in thickness from 125 to 475 ft. The Lockport Dolomite is massive in structure, open to vesicular in texture, light gray to bluish gray, and granular or crystalline. It consists mainly of calcium-magnesium carbonate.

4.2.2 Hydrogeology

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

Monitoring wells installed at the site were completed in the unconsolidated overburden (S wells), the top 10 ft of bedrock (I wells), or greater than 20 ft beneath the top of bedrock (B wells). Monitoring well construction details, hydraulic conductivity data, and historical water level data are provided in Attachment 2.

4.3 Constituents of Concern

FUSRAP-related COCs at the site consist of beryllium, lead, Ra226, Th230, U234 and U238. Lead was identified as a FUSRAP-related COC because lead oxide was used as an additive in the beryllium production process.

4.3.1 Clean-up Goals

Clean-up goals for FUSRAP COCs within soils, fill and debris at the Luckey Site are listed below.

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FUSRAP Cleanup Goals

COC Cleanup Goal

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

The cleanup goals for radionuclides in soil, fill and debris represent activity levels above site average background activity corresponding to a total effective dose equivalent to 25 millirems/year (mrem/yr).

If a mixture of radionuclides is present, the sum of the ratios (SOR) applies per “Multi Agency Radiation Survey and Site Investigation Manual” (MARSSIM) and the ratio should not exceed unity (DOD, 2000).

The 25 mrem/yr soil cleanup goal for unrestricted use (subsistence farmer) for the Luckey Site yields the following SOR equation:

SOR =

Ra226

2.0 pCi/g

Th230

5.80 pCi/g

U234

26 pCi/g

U238 26 pCi/g where:

SOR = sum of ratios

Ra226 = net Ra226concentrations above average background (1.75 pCi/g)

Th230 = net Th230concentrations above average background (2.11 pCi/g)

U234 = net U234concentrations above average background (1.48 pCi/g)

U238 = net U238concentrations above average background (1.63 pCi/g)

4.3.2 FUSRAP-Contaminated Media/Areas

FUSRAP-contaminated media (soils, sediments, fill, and debris) is defined as media located in areas of the Luckey Site that correspond to previous disposal activities, material handling activities, and sediment transport by site drainage features and exceed the clean up goals as specified in Section 4.3.1.

The extent of FUSRAP- contaminated soils, fill, and debris is illustrated on the following figures located in Appendix A:

• Figure 4 shows the modeled lateral extent of soils, fill, and debris contaminated by beryllium, lead, and radionuclides above cleanup goals specified in Section 4.3.1.

• Figure 5 shows the modeled lateral extent and maximum depths of soils, fill, and debris contaminated by beryllium, lead, and radionuclides above cleanup goals specified in Section 4.3.1.

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A summary of the volume estimate methodology, results, analytical data, and the associated volume estimates are provided as Attachment 3.

4.3.2.1 Lagoons

Four lagoons (labeled A, B, C, and D) were used at the site (Appendix A - Figure 3). The lagoons were formed by constructing embankments with scraped soil and lining the structures with compacted clay.

Lagoon A was approximately 3 to 4 ft deep. Lagoon B was constructed in two stages; the first stage was built in 1949 and was approximately 3 to 4 ft deep, the second stage was built in 1950 and was approximately 5 to 6 ft deep. Lagoon C was 1½ ft deep and also constructed in two stages.

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

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

FUSRAP-contamination in the former lagoons predominately occurs to a depth of 5 ft below ground surface (bgs) and in isolated areas to 10 ft bgs.

4.3.2.2 Disposal Pits / Diked Disposal Area

Two scrap disposal pits (Trenches 2 and 7) were confirmed at the site (Appendix A - Figure 3). Trench 7 (approximate 150 ft by 12 ft in dimension) was located between two railroad spurs in the east central portion of the site and Trench 2 was located in the northeast corner of the site (approximate 250 ft by 90 ft in dimension), adjacent to the east fence. Figure 3 (Appendix A) indicates the approximate locations of these pits. The pits were reportedly dug to a depth of approximately 6 ft and completed in native clay soils. Soil from the pit excavations was used as cover after they were full (Cline, 1990).

Descriptive logs of soil borings and an exploratory trench excavated in the 150 ft by 12 ft pit indicate that fill material consisting of steel and fiberboard drums, metal, wood, brick, black sand, and glass fragments was encountered to a depth of approximately 12 ft bgs. Descriptive logs of soil borings drilled in the vicinity of the 250 ft by 90 ft pit identify a black or gray sludge to a depth of approximately 8 ft bgs.

An approximate 2-acre diked disposal area was built in the northeast corner of the site at plant closing.

The disposal area was approximately 2 ft deep and constructed with a clay bottom. Sludges from lagoons A, B, and C were reportedly placed in the disposal area (Cline, 1990). Figure 3 (Appendix A) and historical documents provided in Attachment 1 identify the approximate locations and features of the disposal pits, diked disposal area, and appurtenances.

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

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4.3.2.3 Sewage Treatment Plant

A sewage treatment plant was located north of the production building (Appendix A - Figure 3). The plant received only sanitary wastes (not process wastes) and contained the structures listed below.

Sewage treatment plant drawings are provided in Attachment 1.

• Septic tank

• Pump room and wet well

• Aeration tank and settling tank

• 2,000-gallon dosing tank

• Sand filters

Buried fill has been confirmed in Trench 5, northeast of the sand filters. Descriptive logs of soil borings (Attachment 2) drilled in this area identify fill between approximately 3 and 6.5½ ft bgs that consists of metal debris, wood, ash, brick, woven fabric, black sand, and glass fragments. FUSRAP- contaminated soils and fill are present to depths of 10 and 15 ft bgs.

FUSRAP- contaminated soil and fill are also present south, east and west of the sewage treatment plant in areas associated with previous material handling / storage activities. These areas are described below.

4.3.2.4 Material Handling / Storage Areas

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

Approximately 1,000 tons of radioactive scrap metal from the Lake Ontario Storage Area (New York State) was brought to the site in 1951 and 1952 for use in a magnesium reduction process, which never occurred. The scrap metal was stored north of the production building. The approximate locations of these storage areas are illustrated on Figure 3 (Appendix A) and in historical documents provided in Attachment 1.

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

West of the sewage treatment plant is a bare spot / stressed vegetation area that contains FUSRAP-contaminated soils from ground surface to depths of between 5 ft bgs and 10 ft bgs. (Appendix A - Figure 3)

Two water supply wells (east well and west well) are located north of the production buildings. Both are open bedrock wells that penetrate the Lockport Dolomite. Steel casing was used in the well construction to seal off the unconsolidated overburden. Solids from water softening processes

4-6 associated with the pumping of these wells were stored in the northwest corner of the site. A single, isolated exceedance of lead has been documented in this area.

4.3.2.5 Buildings

Previous surveys and analyses conducted to investigate the potential for FUSRAP contaminants within the on-site buildings included a radiological survey, beryllium and radionuclide swipe surveys, and analysis of bulk dust samples. Results of these surveys and analyses are summarized below and described in greater detail in Section 2.1.4 of the RI Report (USACE, 2000).

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

• Beryllium swipe samples identified removable contamination in the production annex (now demolished), production building, laboratory, and maintenance office building. Lower concentrations of beryllium were also identified in the former melting, alloying and shipping building, shack, east / west extraction well buildings, fire pump house, guard house, production annex, sewage treatment plant pump house, and employee activity building.

• Bulk dust samples contained beryllium at concentrations that were interpreted to indicate that there is a potential to exceed the USACE Occupational Exposure Limit of 0.2 micrograms per cubic meter (µg/m3) and Action Level of 0.1 µg/m3 if dust is re-suspended during disruptive activities.

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

Elevated beryllium has also been detected in subsurface soil samples collected adjacent to and beneath the production annex (refer to Appendix A - Figures 4 and 5). The extent of contaminated soil beneath the buildings has not been fully delineated.

Note that demolition and scrapping activities have been performed since the RI.

4.3.2.6 Underground Utilities

FUSRAP-contamination has been identified in manholes and in soil surrounding underground utility lines identified below and illustrated on Figure 3 (Appendix A).

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

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

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

4.3.2.7 Drainage Ditches

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FUSRAP- contaminated sediment is present within and adjacent to the main drainage ditch on the site and north of the property boundary (Appendix A - Figures 4 and 5). FUSRAP- contamination occurs within the upper 1 ft of sediment / soil within the ditch and on the bank immediately east of the ditch.

The contaminated soil / sediment east of the ditch may represent materials that were previously excavated from the ditch.

4.3.3 Organic Contaminants

Organic contaminants have been detected in site soils during the RI. The concentrations and locations / depths of these compounds in soil are identified in the RI Report (USACE, 2000) and are summarized below. The approximate locations of these contaminated areas area all shown on Figure 3 (Appendix A).

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

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

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

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

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

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