Site Operations Plan for the Luckey Formerly Utilized ......Project organization chart. ..... 26...

PLN-5500 Rev. 1

Site Operations Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project

U.S. Army Corps of Engineers Buffalo District, Buffalo, New York

Applicability: Luckey FUSRAP Remediation

Effective Date: 08/01/17 Owner: Project Manager

Signature

SITE OPERATIONS PLAN FOR THE LUCKEY FORMERLY UTILIZED SITES REMEDIAL ACTION

PROGRAM REMEDIATION PROJECT

Identifier: Revision: Page:

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History of Revisions

Revision Issue Date Action Description

0 05/17/17 New document. Initial Issue.

2 08/01/2017 Revise document. Incorporation of stakeholder comments.




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Table of Contents

1. INTRODUCTION ................................................................................................................12

1.1 Purpose and Approach ..............................................................................................12

1.2 Site Operations Plan Organization ...........................................................................12

1.3 Project Schedule .......................................................................................................14

1.3.1 Work Hours .............................................................................................14

2. SITE DESCRIPTION ...........................................................................................................14

2.1 Site Location .............................................................................................................14

2.2 Site History ...............................................................................................................16

3. ORGANIZATION AND RESPONSIBILITIES ..................................................................23

3.1 USACE Responsibilities ..........................................................................................23

3.2 Portage Responsibilities and Personnel ....................................................................24

3.2.1 Program Manager ....................................................................................24 3.2.2 Project Manager .......................................................................................25 3.2.3 Safety and Health Manager .....................................................................27 3.2.4 Radiation Safety Officer ..........................................................................27 3.2.5 Site Superintendent ..................................................................................28 3.2.6 Site Safety and Health Officer .................................................................28 3.2.7 Construction Quality Control System Manager ......................................29 3.2.8 Waste Manager ........................................................................................29 3.2.9 Project Chemist .......................................................................................30 3.2.10 Cost Scheduler .........................................................................................30 3.2.11 Field Team ...............................................................................................31

3.3 Subcontractors ..........................................................................................................32

3.3.1 Land Surveyor .........................................................................................32 3.3.2 Off-Site Analytical Laboratories .............................................................32 3.3.3 Transport and Disposal of Radiologically Contaminated Soil and

Debris ......................................................................................................33




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4. PHASE I – PREMOBILIZATION ACTIVITIES ................................................................33

4.1 Site-Specific Project Plans .......................................................................................33

4.1.1 Water Management Plan .........................................................................33 4.1.2 Contractor Quality Control Plan ..............................................................34 4.1.3 Accident Prevention Plan/Site Safety and Health Plan/Chronic Beryllium

Disease Prevention Program/Radiation Protection Plan .........................35 4.1.4 Contamination Control Plan ....................................................................36 4.1.5 Sampling and Analysis Plan ....................................................................38 4.1.6 Backfill and Restoration Plan ..................................................................38 4.1.7 Regulatory Compliance Plan ...................................................................39 4.1.8 Waste Management, Transportation, and Disposal Plan .........................39 4.1.9 Final Status Survey Plan ..........................................................................40

4.2 Procuring Equipment, Materials, and Specialty Services ........................................41

4.3 Submittals .................................................................................................................41

5. PHASE II – MOBILIZATION ............................................................................................41

5.1 Administrative Area and Support Zone Preparation and Mobilization ....................49

5.1.1 Personnel Hiring and Training ................................................................50 5.1.2 Signage and Security ...............................................................................50 5.1.3 Clearing and Grubbing ............................................................................51 5.1.4 Fencing ....................................................................................................51 5.1.5 Stormwater and Sediment Controls .........................................................52 5.1.6 Parking Lot and Roads ............................................................................52 5.1.7 Installation and Initiation of Background Air Sampling .........................53 5.1.8 Facilities Mobilization and Installation ...................................................54 5.1.9 Utilities Installation .................................................................................55 5.1.10 Setup and Accreditation of On-Site Laboratory ......................................57

5.2 S1 Area Preparation and Mobilization .....................................................................59

5.2.1 Treating and Excavating Contaminated Soil from S1 .............................60 5.2.2 S1 Infrastructure Installation ...................................................................61 5.2.3 S1 Waste Processing Equipment and Facility Installation ......................65 5.2.4 Water Management and Effluent Monitoring .........................................66 5.2.5 Final Exclusion Zone Setup .....................................................................67




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5.3 Site Layout ...............................................................................................................68

5.3.1 Parking and Site Access ..........................................................................68 5.3.2 Traffic Flow .............................................................................................68 5.3.3 Support Trailers and Facilities .................................................................69 5.3.4 Waste Staging Area .................................................................................69 5.3.5 Water Treatment Facility .........................................................................69 5.3.6 Material and Equipment Storage Yard ....................................................69 5.3.7 Decontamination Facilities ......................................................................69 5.3.8 Contamination Zones ...............................................................................70 5.3.9 On-Site Laboratory ..................................................................................70

6. PHASE III – REMEDIATION ............................................................................................71

6.1 Preparation Exclusion Areas ....................................................................................71

6.2 Overall Excavation Approach ..................................................................................73

6.2.1 Deep Excavation Management ................................................................73 6.2.2 Excavation Control ..................................................................................74 6.2.3 Material Handling Equipment .................................................................74

6.3 Material Sorting and Processing ...............................................................................75

6.3.1 Waste Types and Disposal .......................................................................75 6.3.2 In Ssitu Treatment of Lead-Contaminated FUSRAP Waste ...................76 6.3.3 Waste Sorting ..........................................................................................76 6.3.4 Ra-226-Contaminated FUSRAP Waste ..................................................77 6.3.5 NonFUSRAP Chemical-Contaminated Soil ............................................77 6.3.6 Beryllium-Contaminated FUSRAP Waste ..............................................77 6.3.7 Acceptable Place-Back Soil ....................................................................78 6.3.8 Debris Processing ....................................................................................79

6.4 Waste Packaging and Disposal .................................................................................79

6.4.1 Packaging Waste for Off-Site Transport .................................................79 6.4.2 Radiological and Beryllium Surveys of Waste Containers .....................80 6.4.3 Off-Site Waste Transportation and Disposal ...........................................80

6.5 Spill Prevention and Control ....................................................................................81

6.6 Air Monitoring and Dosimetry .................................................................................81




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6.7 Equipment Decontamination ....................................................................................81

7. FINAL STATUS SURVEY .................................................................................................82

8. DEMOBILIZATION ...........................................................................................................84

9. CONSTRUCTION COMPLETION REPORT ....................................................................84

10. REFERENCES .....................................................................................................................86

APPENDIX A Project Schedule

APPENDIX B Résumés of Key Project Personnel

APPENDIX C Drawings

ATTACHMENT 1 Soil Sorting Operations Plan

Figures

Figure 2-1. Site location map. ....................................................................................................... 15 Figure 2-2. Site layout................................................................................................................... 19 Figure 3-1. Project organization chart. ......................................................................................... 26 Figure 5-1. Site layout for support zone and administrative area preparation (characterization). 43 Figure 5-2. Site layout for support zone and administrative area mobilization (construction). ... 44 Figure 5-3. Site layout for S1 area preparation (characterization and soil treatment/excavation)........................................................................................................................................................ 45 Figure 5-4. Site layout for S1 area mobilization (construction). .................................................. 46 Figure 5-5. Final site plan, site-wide view (including perimeter air monitoring locations). ........ 47 Figure 5-6. Final site plan, detail view. ........................................................................................ 48 Figure 5-7. Typical place-back stockpile cross section for optional eastern stockpiles. .............. 63 Figure 5-8. Plan and profile views of a typical 100-CY stockpile pad. ........................................ 64 Figure 6-1. Waste characterization process and disposition path. ................................................ 78

Tables

Table 3-1. Key project personnel. ................................................................................................. 24 Table 6-1. FUSRAP cleanup goals. .............................................................................................. 71 Table 6-2. Disposal facilities and waste types. ............................................................................. 75




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ACRONYMS AND ABBREVIATIONS

AA administrative area

AEC Atomic Energy Commission

ALARA as low as reasonably achievable

APP accident prevention plan

ARAR applicable or relevant and appropriate requirement

BBC Brush Beryllium Company

Be-LPT beryllium lymphocyte proliferation testing

bgs below ground surface

BRP backfill and restoration plan

CBDPP chronic beryllium disease prevention program

CCP contamination control plan

CFR Code of Federal Regulations

CG cleanup goal

CHP certified health physicist

CHST construction health and safety technician

CIH certified industrial hygienist

COC constituent of concern

COI constituent of interest

CPM critical path method

CQC contractor’s quality control

CQCP contractor quality control plan




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CQCSM construction quality control system manager

CRZ contamination reduction zone

CY cubic yard

DoD U.S. Department of Defense

DOT U.S. Department of Transportation

DQO data quality objective

EM engineer manual

EZ exclusion zone

FSS final status survey

FSSP final status survey plan

ft foot (feet)

FUSRAP Formerly Utilized Sites Remedial Action Program

gpm gallons per minute

GPS Global Positioning System

HP health physicist/health physics

IH industrial hygiene

in. inch(es)

in situ in the natural or original position or place

IPR Industrial Properties Recovery, LLC

ISO International Standards Organization

KO contracting officer

MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual




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NPDES National Pollutant Discharge Elimination System

NRC Nuclear Regulatory Commission

NREMR nationally registered emergency medical responder

NRRPT National Registry of Radiation Protection Technologists

NTP notice to proceed

OAC Ohio Administrative Code

ODH Ohio Department of Health

OEPA Ohio Environmental Protection Agency

OHST occupational health and safety technologist

ORC Ohio Revised Code

OSH occupational safety and health

OSHA Occupational Safety and Health Administration

PAMP perimeter air monitoring plan

PCB polychlorinated biphenyl

PE professional engineer

PG professional geologist

PgM program manager

PM project manager

PMP project management professional

PM-10 particulate matter 10 micrometers in diameter or smaller

PPE personal protective equipment

QA quality assurance




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QC quality control

QCS quality control system

Ra radium

RCA radiological control area

RCP regulatory compliance plan

RCRA Resource Conservation and Recovery Act

RI remedial investigation

RO reverse osmosis

ROD record of decision

RPP radiation protection plan

RSO radiation safety officer

S&H safety and health

SAP sampling and analysis plan

SHM Safety and Health manager

SOP site operations plan

SOW scope of work

SSHO site safety and health officer

SSHP site safety and health plan

SSOP soil sorting operations plan

STSC Safety Trained Supervisor Construction

SVOC semivolatile organic compound

SWPPP stormwater pollution prevention plan




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SZ support zone

TCLP toxicity characteristic leaching procedure

TENORM technologically enhanced, naturally occurring radioactive material

Th thorium

TLD thermoluminescent dosimeter

TRPH total recoverable petroleum hydrocarbons

TSDF treatment, storage, and disposal facility

TSP total suspended particulate

U uranium

UFGS Unified Facilities Guide Specification

USACE United States Army Corps of Engineers

USEI US Ecology, Inc.

USEPA United States Environmental Protection Agency

VOC volatile organic compound

WM Inc. Waste Management, Inc.

WMP water management plan

WMTDP waste management, transportation, and disposal plan




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1. INTRODUCTION

1.1 Purpose and Approach

The United States Army Corps of Engineers (USACE) – Buffalo District has selected Portage, Inc., under Contract Number W912P4-15-D-0006 to remediate the Luckey Site in Luckey, Ohio. Portage is remediating the site under the USACE’s Formerly Utilized Sites Remedial Action Program (FUSRAP), which was established to identify, investigate, and clean up or control sites previously used by the Atomic Energy Commission (AEC) and its predecessor, the Manhattan Engineer District. Materials on the site are contaminated with FUSRAP-related constituents of concern (COCs), which include beryllium, lead, radium-226 (Ra-226), thorium-230 (Th-230), uranium-234 (U-234), and uranium-238 (U-238).

The primary objective of the remediation project is the timely and effective cleanup of the site in accordance with the Luckey Site Record of Decision (ROD) for Soils Operable Unit, Final (USACE 2006). The selected remedial alternative calls for excavating impacted soils, including on-site and off-site contiguous soils where contamination has migrated through natural means. The aim is to achieve cleanup goals for unrestricted use by the critical group, the subsistence farmer. Portage will place clean backfill and acceptable place-back in excavated areas. It will ship excavated soils off-site for disposal at a licensed/permitted disposal facility. This alternative meets the evaluation criteria while protecting human health and the environment; it complies with applicable or relevant and appropriate requirements (ARARs). Portage will remediate the site so as to provide a level of protection to the public and remediation workers consistent with applicable exposure requirements and with the objective of maintaining chemical and radiological exposure levels as low as reasonably achievable (ALARA).

1.2 Site Operations Plan Organization

This site operations plan (SOP) presents methods, procedures, and facilities that will be used to complete remediation in accordance with USACE guidelines, maintaining a safe and productive work environment. This SOP describes the overall plan for completing the mobilization, remediation, and restoration of the site and provides information required in the Final Scope of Work, Remediation of Soils Operable Unit, Luckey Site (SOW) (USACE 2014a). This SOP addresses Phase II – Infrastructure, Operations, and Maintenance; excavation activities are addressed only in general. As task orders are issued, subsequent revisions will address Phase III – Remediation. Specifically, this SOP describes the:

• Project organization and responsibilities.

• Key project personnel (including résumés and certifications) and primary subcontractors.

• Supporting utilities and facilities.




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• Equipment and materials.

• Excavation, sorting, processing and packaging procedures, and methods.

• Methods for processing oversized materials before packaging and transport for off-site disposal.

• Dust control procedures during excavation and on-site transportation of trench materials.

• Critical path method (CPM) project schedule.

This SOP is based on information available at the time of its preparation. Future task orders, conditions encountered, and findings as remediation progresses may necessitate revision to this SOP. If modifications become necessary, they will be justified, documented, and approved by the USACE before implementation. The SOP is an overarching plan with specific requirements and procedures identified in the following ancillary plans by work element:

• Water Management Plan (WMP) for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project (USACE 2016a)

• Contractor Quality Control Plan (CQCP) for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project (USACE 2016b)

• Accident Prevention Plan/Site Safety and Health Plan (APP/SSHP) for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project (USACE 2016c), including the attachments: o Chronic Beryllium Disease Prevention Program (CBDPP) for the Luckey Formerly

Utilized Sites Remedial Action Program Remediation Project (USACE 2016d) o Radiation Protection Plan (RPP) for the Luckey Formerly Utilized Sites Remedial

Action Program Remediation Project (USACE 2016e)

• Contamination Control Plan (CCP) for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project (USACE 2016f)

• Uniform Federal Policy Quality Assurance Project Plan for the Luckey Formerly Utilized Sites Remedial Action Program Site Remediation, Luckey, Ohio, Sampling and Analysis Plan (SAP) (USACE 2016g)

• Backfill and Restoration Plan (BRP) for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project (USACE 2016h)

• Regulatory Compliance Plan (RCP) for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project (USACE 2016i)




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• Waste Management, Transportation, and Disposal Plan (WMTDP) for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project (USACE 2016j)

• Final Status Survey Plan (FSSP) for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project (USACE 2016k).

1.3 Project Schedule

A CPM schedule for work plan development and mobilization is presented in Appendix A of this SOP. The availability of funds will dictate the sequencing of work, and the schedule will be revised accordingly with USACE approval.

1.3.1 Work Hours

Standard work hours for the site will be 6:00 a.m. to 4:30 p.m. Monday through Thursday. The site will be closed for the following holidays: New Year’s Day, Presidents’ Day, Memorial Day, Independence Day, Labor Day, Thanksgiving Day, day after Thanksgiving Day, and Christmas.

2. SITE DESCRIPTION

2.1 Site Location

The 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 southeast of Toledo, Ohio (see Figure 2-1). The site encompasses approximately 40 acres and contains a large production building and warehouse, two abandoned railroad spurs, and several smaller process and support buildings. The area surrounding the site to the west, north, and east is primarily residential farmland. From 1949 to the early 1960s, the Brush Beryllium Company, as a contractor to the AEC, used the site for beryllium processing to support the national defense program. Beryllium production brought different types of source media and potential contaminants to the site. Primary source media included materials delivered for processing or reprocessing: beryl ore from Africa and South America, scrap beryllium, and radiologically contaminated scrap steel.




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Figure 2-1. Site location map.




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2.2 Site History

In 1942, a magnesium reduction facility was built at the site on U.S. government land. National Lead operated the facility for the U.S. government 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 site facilities were owned by the AEC and operated by BBC from 1949 to 1958. During nonpeak 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 radiologically contaminated beryllium scrap from other AEC operations may have been sent to the site. BBC ceased beryllium production in 1958. 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 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 to Aluminum and Magnesium, Inc. The facility was then used to recover zinc from byproducts of the steel industry. In1967, Aluminum and Magnesium, Inc., transferred the property to its parent company, the Vulcan Materials Company.

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., is the successor company to Motor Wheel. From 1995 to 2004, Hayes Lemmerz 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. During December 2006, the Ohio Department of Health (ODH) issued an Emergency Adjudication Order to IPR, to cease demolition of buildings and handling of radioactive material.




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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 in June 2009. The injunction required 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. In December 2013, the ODH issued another Emergency Adjudication Order against IPR to halt demolition activities again.

There are several large buildings and smaller structures at the site that had been built to house or support magnesium production activities and subsequently were used during beryllium processing and sintering activities (see Figure 2-2).

Large buildings at the site:

• Production building.

• Production annex.

• Melting, alloying, and shipping building.

• Laboratory building.

• Maintenance office building.

• Main office.

• Employee activity building.

Small structures at the site:

• Pump house (for fire protection water).

• East and west well houses.

• Guard house.

• Shack.

• 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 in shape. 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. The production annex building has been demolished and only the building floor slab and demolition debris remain.




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

Media contaminated by FUSRAP-related constituents include soils, sediments, fill, and debris. The contamination of these media exceeds the ROD’s established cleanup values. Documented material handling and disposal areas at the site, as reflected in Figure 2-2, included:

• 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 groundwater.

Details about these areas are discussed below.

Lagoons Four lagoons (labeled A, B, C, and D) were used at the site. The lagoons were formed by constructing embankments with scraped soil and lining the structures with compacted clay. Lagoon A was approximately 3 to 4 feet (ft) deep. Lagoon B was constructed in two stages: the first stage was built in 1949 and was approximately 3 to 4 ft deep, and the second stage was built in 1950 and was approximately 5 to 6 ft deep. Lagoon C was 1 1/2 ft deep and was 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 stormwater retention but did not receive any process water. The lack of contamination in the area of Lagoon D, as shown through the characterization data from the RI (USACE 2000), supported the assumption that Lagoon D was not used for the storage of process water. No details of the Lagoon D construction are available.




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Figure 2-2. Site layout.




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Most lagoon sludges were removed at plant closing (1959) and placed in a diked disposal area constructed in the northeast corner of the site. After closure, the lagoon dikes and embankments were used to fill the lagoons. A 2-ft-thick clay cap was installed on Lagoons A and B in 1988.

FUSRAP contaminants in the former lagoons predominantly occur to a depth of 5 ft below ground surface (bgs) and in isolated areas to 10 ft bgs.

Disposal Pits/Diked Disposal Area The remedial investigation (RI) report (USACE 2000) and the ROD identified up to seven trenches at the site. The sludge from Lagoons A, B, and C was dredged every summer and placed into disposal trenches in the northeast corner of the facility (Trenches 1 through 4). Also, a 2-acre, 2-ft-deep, clay-bottom, diked disposal area was built in the northeast corner of the site at plant closing for remaining sludge. Scrap metal, building debris, and graphite crucibles with soluble beryllium fluoride, and possibly sludge from Lagoons A, B, and C, were placed into excavated trenches (Trenches 5, 6, and 7).

The U.S. Army Corps of Engineers confirmed three disposal pits (potentially Trenches 2, 5, and 7) by direct sampling. The Corps of Engineers located Trench 2 in the northeast corner of the site (approximately 250 by 90 ft), adjacent to the east fence. Descriptive logs of soil borings drilled in Trench 2 identify a black or gray sludge to a depth of approximately 8 ft bgs. The Corps confirmed buried fill in Trench 5, northeast of the sand filters. Descriptive logs of soil borings drilled in this area identify fill between approximately 3 and 6.5 ft bgs that consists of metal debris, wood, ash, brick, woven fabric, black sand, and glass fragments. The Corps located Trench 7 (approximately 150 by 12 ft) between two railroad spurs in the east-central portion of the site. Descriptive logs of soil borings and an exploratory trench 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. Based on physical data and geophysical surveys, the estimated boundaries for all seven trenches are shown in Figure 2-2.

Sampling from potential trench areas indicates that FUSRAP-contaminated soils and fill materials occur to 13 ft bgs in the vicinity of Trench 7, 10‒12 ft bgs at Trenches 5 and 6, and more than 18 ft bgs across Trenches 1–4. Sampling, historical records, and worker interviews indicate that multiple disposal activities occurred around Trenches 1‒4 and the disposal area, resulting in a nearly contiguous region of FUSRAP-contaminated soil and fill; whereas the Corps of Engineers anticipates Trenches 5, 6, and 7 will be distinct pits bordered by native materials.

Sewage Treatment Plant A sewage treatment plant was located north of the production building. The plant received only sanitary wastes (not process wastes) and contained the structures listed below:

• Septic tank.




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• Pump room and wet well.

• Aeration tank and settling tank.

• 2,000-gallon dosing tank.

• Sand filters.

FUSRAP-contaminated soils and fill are present down to depths of 10 and 15 ft bgs. FUSRAP-contaminated soils 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.

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 soils 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 shipped by AEC 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.

Piles of debris from ore staging and disposal activities are located south and east of the sewage treatment plant sand filters. FUSRAP-contaminated soils and fill in these areas are present primarily from the ground surface to 5 ft bgs. FUSRAP contaminants extend to 10 ft bgs in areas east and southeast of the sand filters.

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

Two water supply wells (east well and west well) are located north of the production buildings. Both are open bedrock wells that penetrate the Lockport dolomite. Steel casing was used in the well construction to seal off the unconsolidated overburden. Solids from water softening processes associated with the pumping of these wells were stored in the northwest corner of the site. A single, isolated exceedance of lead has been documented in this area.

Buildings Previous surveys and analyses conducted as part of the Phase II characterization 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.




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• 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. 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 resuspended 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. The extent of contaminated soil beneath the buildings has not been fully delineated.

Underground Utilities FUSRAP contaminants have been identified in manholes and in soil surrounding underground utility lines, as identified below:

• 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 manholes (MH28 and 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.

Drainage Ditches FUSRAP-contaminated sediment is present within and adjacent to the main drainage ditch on the site and north of the property boundary. FUSRAP contaminants occur within the upper 1 ft of sediment/soil within the ditch and on the bank immediately east of the ditch. The contaminated




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

Organic Contaminants Organic contaminants were detected in site soils during the RI. The concentrations and depths of these compounds in soil are identified in the RI Report (USACE 2000) and are summarized below:

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

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

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

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

3. ORGANIZATION AND RESPONSIBILITIES

This section describes the project organization and responsibilities of personnel directing and performing remediation. A list of key project personnel is provided as Table 3-1 and résumés of key Portage personnel are included in Appendix B. A project organization chart is provided as Figure 3-1.

3.1 USACE Responsibilities

The Buffalo District of USACE is responsible for project management, technical support, and project engineering at the site.




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Table 3-1. Key project personnel. TITLE NAME TELEPHONE

Stakeholders: Ohio Environmental Protection Agency Ohio Department of Health

U.S. Army Corps of Engineers – Buffalo District: USACE Project Manager USACE Contract Officer USACE Contract Officer Representative USACE Contract Officer Representative USACE Project Engineer USACE Health Physicist USACE Industrial Hygienist USACE Chemist USACE Senior Health Physicist

Portage: Program Manager Project Manager Safety and Health Manager Radiation Safety Officer Site Superintendent Site Safety and Health Officer Project Chemist Construction Quality Control System Mgr Waste Manager

3.2 Portage Responsibilities and Personnel

3.2.1 Program Manager

Portage’s program manager (PgM) is , project management professional (PMP), and registered professional engineer (PE) in Ohio. He has ultimate responsibility for overall management of the contract, including safety, material accounting, reporting, waste disposal, cost, schedule and technical quality, and compliance with all contract terms and conditions. He acts as the single point of accountability with USACE for safe, cost-effective, and timely quality of work. He has responsibility for committing resources and will interface with the Portage corporate office and team member principals.

The PgM has authority to:

• Execute all contract terms.

• Approve invoices, subcontracts, and procurements.




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• Approve project work plans, schedules, and budgets.

• Approve formal correspondence with the USACE.

• Stop work.

3.2.2 Project Manager

Portage’s project manager (PM) is . The PM reports directly to the PgM and is responsible for managing and executing task orders in accordance with the approved statement of work and work plans, and all federal, state, and local laws and regulations. The PM is responsible for ensuring that all work associated with each task is planned, and work packages are generated and approved with participation from all applicable contractor functional disciplines, i.e., occupational safety and health (OSH), industrial hygiene (IH), health physics (HP), data acquisition management, quality assurance/quality control (QA/QC), training, security, and crafts (equipment operators, labor, etc.). He is responsible for ensuring that all task performance prerequisites are complete; hazards and hazard controls are identified and communicated to all personnel associated with the task; equipment, tools, and materials necessary to perform the task are available, sufficient, and adequate with all necessary inspections, calibration, and testing complete; sufficient staff is present to execute the task; staff training and qualifications are complete; and personnel understand roles, responsibilities, and authorities, including the bounding conditions that if challenged, warrant work suspension; and any necessary exercises, simulations, mock-ups, etc., are complete. The PM is responsible for ensuring that all work performance requirements are implemented and adhered to during execution; that internal assessments are routinely performed; and deficiencies are identified, corrected, and communicated.

The PM has authority to:

• Stop work for unsafe or quality-impacting conditions.

• Review/approve/implement work plans.

• Approve deliverables/reports.

• Approve personnel assignments.




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Figure 3-1. Project organization chart.




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3.2.3 Safety and Health Manager

, certified industrial hygienist (CIH), is Portage’s safety and health manager (SHM), reporting to the Portage corporate health and safety manager. The SHM is responsible for developing and implementing a comprehensive safety program for the Luckey project (APP/SSHP/CBDPP/RPP). The SHM is responsible for ensuring that safety/industrial hygiene (IH) procedures are complete; technical and field OSH/IH personnel necessary to execute project tasks are trained and qualified commensurate with assigned responsibilities; all project personnel are trained on safety-related topics commensurate with assigned duties and responsibilities; and OSH/IH hazards and hazard controls are properly addressed in the design of new facilities or processes or modification of same (with emphasis on hazard elimination). He is also responsible for ensuring that OSH/IH hazards and hazard controls are identified during work planning and development; integrated hazard analyses/controls are developed for each task; and safety/IH equipment, tools, and materials necessary for task execution are available, calibrated, and tested, as necessary.

The SHM is responsible for ensuring that work area inspections are performed before the start of work and periodically throughout task execution; exposure monitoring is conducted and personnel are informed of results; OSH/IH records are generated and retained as required by the APP/SSHP; and program or performance issues are identified, corrected, and communicated.

The SHM has authority to:

• Stop work for unsafe or quality-impacting conditions. • Approve and enforce the APP/SSHP. • Conduct and approve safety and health (S&H) audits and assessments, findings, and

corrective actions. • Direct the site safety and health officer (SSHO) and assign site safety personnel.

3.2.4 Radiation Safety Officer

Portage’s radiation safety officer (RSO) is , a certified health physicist (CHP). The RSO reports directly to the SHM and is responsible for developing and implementing the RPP for the Luckey project. The RSO is responsible for ensuring that radiation safety procedures are complete; technical and field radiation safety personnel necessary to execute project tasks are trained and qualified commensurate with assigned responsibilities; and all project personnel are trained on radiation safety-related topics commensurate with assigned duties and responsibilities. He is responsible for ensuring that occupational radiation hazards and hazard controls are properly addressed in the design of new facilities or processes or modification of same (with emphasis on hazard elimination), and that radiation hazards and hazard controls are identified during work planning and development of integrated hazard analyses/controls for each task. The




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RSO is also responsible for ensuring that radiation safety equipment, tools, and materials necessary for task execution are available, calibrated, and tested, as necessary; work area inspections are performed before the start of work and periodically throughout task execution; exposure monitoring is conducted, and personnel are informed of results; radiation safety records are generated and retained as required by the RPP; and program or performance issues are identified, corrected, and communicated.

The RSO has authority to:

• Stop work for unsafe or quality-impacting conditions. • Approve and enforce the RPP. • Assign and manage field radiological protection resources. • Approve final status survey results.

3.2.5 Site Superintendent

The site superintendent, , reports directly to the PM and is responsible for ensuring that equipment operators, craft, and labor personnel are sufficiently trained and qualified to execute assigned tasks, and assessing and reporting field progress to the PM. He is responsible for supervising field activities, in-house and subcontracted, and coordinating site logistics. The site superintendent shall participate in work planning and work package generation, ensuring that necessary equipment, tools, material, and personnel are identified. The superintendent will also ensure pre-use inspections; calibrations, if required; and QC measurements, if required, are complete and routinely performed as specified. He shall participate in the design of new facilities or systems (or modification of the same), ensuring that human factors issues are incorporated; e.g., unique identification of components and valves; and operational procedures are developed. The site superintendent shall routinely assess work activities to ensure tasks are performed in accordance with the requirements detailed in work packages, that field personnel are trained and qualified, and equipment is inspected and adequate.

The site superintendent has authority to:


• Direct field work activities and establish field priorities.

• Review field QC reports and field documentation.

3.2.6 Site Safety and Health Officer

The project site safety and health officer (SSHO), , construction health and safety technician (CHST), occupational health and safety technologist (OHST), and nationally




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registered emergency medical responder (NREMR), reports directly to the SHM. The SSHO is responsible for ensuring that all elements of the approved APP/SSHP, CBDPP, and RPP are implemented and enforced on-site. The SSHO shall participate in developing the APP/SSHP, CBDPP, and RPP, as appropriate; work planning; and developing the integrated safety analyses, including specification of OSH/IH hazard controls; and developing work packages to address task execution. The SSHO is responsible for conducting safety and health inspections/ assessments and maintaining a safety and health deficiency tracking system. He is responsible for conducting investigations for injuries, accidents, and near misses, and for completing required reports. The SSHO is responsible for ensuring that exposure monitoring is conducted and personnel are informed of the results, and ensuring that testing/monitoring is performed to document employee exposure to hazards.

The SSHO has authority to:


• Review, approve, and enforce the APP/SSHP, CBDPP, and RPP.

3.2.7 Construction Quality Control System Manager

The construction quality control system manager (CQCSM), , PMP and professional geologist (PG), is responsible for overall management of the USACE’s Quality Control System and has the authority to act in all QC matters. The CQCSM is responsible for developing the CQCP for the Luckey project, ensuring compliance with the requirements identified in the Performance Work Statement, Task Order Scope of Services, the CQCP, and the corporate QA program. The CQCSM is responsible for routine audits and assessments of work performance and ensuring that issues identified are documented in Portage’s corrective action management system, and implementing the three-phase control system for all aspects of work.

The CQCSM has authority to:

• Stop work for unsafe or quality-impacting conditions. • Approve and implement the CQCP. • Assign and direct on-site QC staff. • Approve and verify corrective actions for completeness and effectiveness.

3.2.8 Waste Manager

The waste manager, , National Registry of Radiation Protection Technologists (NRRPT), reports to the PM and acts as a single point of contact for all waste management regulatory matters and has overall responsibility for total waste management and disposal compliance, including—but not limited to—accurately identifying and classifying regulated




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materials, determining proper shipping names, and preparing shipping documents for all materials transported using language with which USACE concurs. He is responsible for completing all exception and discrepancy reports; for identifying and complying with marking, labeling, packaging, and placarding requirements; and for preparing and submitting daily status tracking reports. He is responsible for coordinating with USACE, disposal facility, and transportation agencies as applicable, and preparing and submitting any other documents required by federal, state, and local laws and regulations, by USACE, or by the disposal facility. He is responsible for coordinating review and approval for all manifests.

The waste manager has authority to:

• Direct all aspects of waste management and disposal. • Coordinate approval of manifests by USACE. • Certify that waste satisfies all shipping requirements and complies with the waste

acceptance criteria for the treatment, storage, and disposal facility (TSDF).

3.2.9 Project Chemist

The project chemist, , is responsible for the developing and managing implementation of the SAP, U.S. Environmental Protection Agency (EPA) SW-846, and QC procedures. He is responsible for instructing field personnel about sampling and preservation requirements and performing general oversight of sampling. The project chemist will review analytical data for conformance with quality standards, and prepare/review data validation reports. He is responsible for conducting and overseeing all on-site analytical testing based on the SAP and CCP, including field screening tests.

The project chemist has authority to:

• Approve the SAP.

• Direct all project tasks associated with sampling and analysis.

• Perform quality assessment of data packages from laboratories, including the field laboratory.

3.2.10 Cost Scheduler

The project cost scheduler, will be responsible for maintaining the project schedule and ensuring proper schedule and cost reimbursement.




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3.2.11 Field Team

Field team members are responsible for performing field activities described in this SOP. In addition to the field personnel listed above, the field team members and responsibilities will consist of:

• Radiation Technicians – Radiation technicians report to the RSO and will perform periodic instrument checks and radiological surveys (e.g., scans of waste containers, debris, remediation equipment, and work areas), and collect and prepare soil samples for on-site and off-site laboratory analysis. The radiation technicians will also maintain radiological control areas (RCAs) and controls, perform surveys of personnel and equipment, complete instrument and data records, perform gamma spectroscopy analyses of samples, log data, maintain documentation, and perform instrument QC functions in an on-site radiological laboratory during field remediation, with oversight by the RSO.

• S&H Technicians – S&H technicians report to the SSHO and will assist with evaluations and recommendations regarding safe work practices and the day-to-day monitoring requirements specified in the APP.

• Waste Technicians – The waste technicians report to the waste manager. The waste technicians will support the waste manager in the overall management of wastes generated at the Luckey Site, including waste characterization, waste packaging, and activities in support of waste shipping/disposal.

• ScanSortSM Operations – A ScanSortSM operator and ScanSortSM technician will have responsibility for all ScanSortSM operations, including maintaining the system, ensuring operational functionality of the ScanSortSM system, and managing ancillary equipment such as the feed system, conveyors, and dust suppression system. The ScanSortSM operations staff reports to the site superintendent.

• Craft Labor – Various craft labor, including equipment operators, laborers, truck drivers, and mechanics, will be utilized in the performance of site remediation activities, including excavation, on-site waste transport, water management/treatment, stockpile management, equipment maintenance, etc. This labor force reports to the excavation foreman, who in turn reports directly to the site superintendent.

• Laboratory Technicians/Chemists – Laboratory technicians/chemists will manage, process, prepare, and analyze samples. Laboratory technicians/chemists report to the project chemist.




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3.3 Subcontractors

Subcontractor services will vary as the work is defined or progresses. Specific subcontractor services identified at this point include land surveying, off-site laboratory analyses, and transport and disposal of radiologically contaminated soils and debris.

3.3.1 Land Surveyor

A land surveyor and crew will conduct civil surveys at the following stages of work (at a minimum):

• Before excavation (i.e., existing conditions).

• Weekly.

• Upon completion of excavation but before backfilling.

• Upon completion of backfilling.

• Final site grades.

3.3.2 Off-Site Analytical Laboratories

Based on the capabilities of the on-site laboratory and the need for verification sample analysis, some laboratory analyses will be performed by off-site laboratories. These analyses will cover:

• PCBs.

• Toxicity characteristic leaching procedure (TCLP).

• Additional inorganic capacity.

• Additional organic capacity.

• Additional radiochemistry capacity.

• Asbestos, if necessary.

• Geotechnical samples and/or samples requiring additional geochemical methods.

• A limited number of final status survey (FSS) samples.

Samples requiring off-site analyses will be shipped to the ARS Port Allen laboratory in Port Allen, Louisiana, or to another subcontract laboratory with a radioactive material license.




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3.3.3 Transport and Disposal of Radiologically Contaminated Soil and Debris

The anticipated FUSRAP-related waste streams during site remediation include nonhazardous waste, low-activity radioactive waste, low-activity mixed waste, and Resource Conservation and Recovery Act (RCRA) hazardous waste. Treatment and disposal needs may include Subtitle D landfill, Subtitle C landfill, TSDF (soil treatment for lead), and FUSRAP-related technologically enhanced, naturally occurring radioactive material (TENORM) waste. Beryllium-contaminated waste from Luckey is not considered RCRA-hazardous; however, beryllium does require handling considerations to ensure safety of disposal facility workers.

Waste soil and debris will be transported off-site for disposal as discussed in Section 6.4. Waste containers prepared for transport to the disposal facility will be transported by truck or rail to USACE-accepted TSDFs. Details regarding disposal and transportation are contained in the WMTDP.

4. PHASE I – PREMOBILIZATION ACTIVITIES

This section describes the first phase of the project. It explains the tasks that must be completed before full field mobilization for remediation.

4.1 Site-Specific Project Plans

Preparation of all project work plans is in accordance with the SOW. These documents, including this SOP, may be updated periodically as necessary based on the scheduled review process and potential changes encountered in the field. Major revisions will be reviewed and approved by the USACE and appropriate stakeholders, as required, and directed by the USACE. The most current approved revision for each document will be maintained on-site at Portage’s field project office. A summary of the supporting project work plans is provided below.

4.1.1 Water Management Plan

The WMP addresses managing stormwater and wastewater during site activities. Any water (i.e., precipitation, run-on, used decontamination water, dust control water, and groundwater within an excavation) coming in contact with the contaminated areas and excavations shall be considered potentially contaminated. Portage shall follow the WMP to manage contaminated water discharge and disposal. The WMP describes means and methods to comply with all federal, state, and local regulations and/or guidelines related to water quality, including but not limited to the State of Ohio Water Quality Standards (Ohio Administrative Code [OAC] 3745-1). The WMP details required coordination with local stakeholders including, but not limited to, Ohio EPA.




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The WMP:

• Selects methods for managing potentially contaminated water in the excavations and active work areas within the exclusion zone (i.e. temporary haul roads, stockpile areas, equipment decontamination areas, and equipment use areas).

• Identifies soil and stockpile stabilization practices to be used.

• Describes methods for the collecting, testing, managing, temporarily storing, transporting, and treating potentially contaminated water.

• Provides details of an on-site water treatment facility, such as a process flow diagram, equipment and component capacities, proposed location on-site, and sampling and analysis requirements.

• Provides details on dewatering and water management operations.

• Provides layout and details of the on-site wastewater treatment system.

• Identifies proposed treated water discharge point(s).

• Provides details associated with water storage (e.g., vessel type, size, number, and location on-site), transportation, and off-site treatment facility.

• Identifies reporting requirements.

The stormwater pollution prevention plan (SWPPP):

• Identifies potential sources of pollution that may be reasonably expected to affect the quality of stormwater discharge from the site.

• Describes and ensures the implementation of practices that will be used to control surface water run-on and run-off from the remediation areas (including diversion of noncontaminated run-off around active work areas within the exclusion zone).

• Selects appropriate best management practices from U.S. EPA 833-R-060-04, Developing Your Stormwater Pollution Prevention Plan, A Guide for Construction Sites (May 2007).

• Identifies monitoring and reporting requirements.

4.1.2 Contractor Quality Control Plan

Portage will be responsible for QC and shall establish and maintain an effective QC system. The CQCP is the means by which Portage ensures that construction (subcontractors and suppliers) complies with the contract. Portage must conduct at least three phases of control for each definable feature of the construction work: a preparatory, initial, and follow-up.




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Portage’s QC program will ensure that all documents and design activities required by the SOW are prepared and provided to USACE in a manner that meets professional engineering quality standards. To cover all design and construction operations, both on-site and off-site, including work by subcontractors, fabricators, suppliers, designers of record, consultants, and architects and engineers, the CQCP must include, at a minimum, the following:

• A description of the QC organization. • The name, qualifications (in résumé format), duties, responsibilities, and authorities of

each person assigned a contractor’s quality control (CQC) function. • A copy of a letter to the CQCSM, signed by an authorized official of the firm, which

describes responsibilities and delegates sufficient authorities to adequately perform the functions of the CQCSM, including authority to stop work not in compliance with the contract. Letters of direction to all other various QC representatives outlining duties, authorities, and responsibilities will be issued by the CQCSM. Copies of these letters must be furnished to USACE.

• Procedures for scheduling, reviewing, certifying, and managing submittals. • Control, verification, and acceptance testing procedures for each specific test. • Procedures for tracking preparatory, initial, and follow-up control phases and control,

verification, and acceptance tests, including documentation. • Procedures for tracking construction, design, and construction deficiencies. • Reporting procedures, including proposed reporting formats. • A list of the definable features of work.

4.1.3 Accident Prevention Plan/Site Safety and Health Plan/Chronic Beryllium Disease Prevention Program/Radiation Protection Plan

Portage will develop a site-specific APP/SSHP in accordance with USACE Engineer Manual (EM) 385-1-1, Safety and Health Requirements (USACE 2014b) and the SOW. The APP/SSHP will be developed and submitted in the format provided in Appendix A of USACE EM 385-1-1 and will include all applicable plans, using the APP/SSHP checklist as a guide. Portage will use the site-specific Unified Facilities Guide Specification (UFGS) 01 35 26 (Governmental Safety Requirements) and UFGS 01 35 29.13 (Health, Safety and Emergency Response Procedures for Contaminated Sites) to complete the APP/SSHP.

Portage will complete the APP/SSHP checklist and submit it as an attachment to the APP/SSHP. Portage will complete an activity hazard analysis per EM 385-1-1, 01.A.14, for each work activity and will submit these as attachments to the APP/SSHP. Portage will submit all other relevant safety plans as attachments to the APP/SSHP.




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Portage will prepare a Luckey Site-specific CBDPP as an attachment to the APP/SSHP. Included in the CBDPP will be a baseline inventory and hazard assessment of beryllium contamination on-site. The CBDPP will contain all necessary elements to allow Portage to minimize the number of beryllium-exposed staff, including official visitors and visiting specialists (mechanics, specialty craftsmen for short-term duties, etc.), minimize the amount of beryllium exposure, and minimize the duration of beryllium exposure. The minimum required topics to be addressed in Portage’s CBDPP are presented in the SOW. The CBDPP is not limited to these topics but must receive contracting officer (KO) acceptance before the notice to proceed (NTP) with any site work.

The baseline inventory and hazard assessment will result in the establishment of anticipated work zone boundaries, including the exclusion zone (EZ), contamination reduction zone (CRZ), support zone (SZ), and administrative area (AA). All access points and decontamination areas are to be clearly delineated on the site drawings, which will also indicate where the potential exposure to beryllium exists. The CBDPP-required signage will be in place before NTP with any site work is granted. Personal protective equipment (PPE) requirements, including training for use (donning and doffing), care, and inspection, will be clearly defined for each area and will be based on the potential exposure to beryllium. The SHM will continually assess the potential exposure to beryllium on-site and may modify the work zone boundaries based on additional sampling results and changing activity in each work zone.

Portage will adhere to the USACE occupational exposure limit of 0.2 μg/m3 and action level of 0.1 μg/m3, as indicated in the beryllium exposure standard variance letter for Luckey, to ensure employee protection. Exposure monitoring and air sampling will be performed by a competent person to evaluate the effectiveness of prescribed PPE and to evaluate worker exposure to site-related contaminants and hazardous substances used in the cleanup process.

Portage will develop an RPP commensurate with the scope and extent of the activities and sufficient to ensure compliance with applicable standards. The RPP will be signed by the RSO and attached to the APP/SSHP.

4.1.4 Contamination Control Plan

Portage shall be responsible for creating and maintaining a system for contamination control. Portage will produce a CCP for monitoring and controlling the spread of contamination, whether from soil or airborne emissions, outside of the EZ and site boundary. The CCP must cover all on-site operations, including work by subcontractors, and it must include, at a minimum, the following:

• General methods for minimizing contamination spread.




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• Methods for access/egress control to work zones, including a CRZ, step-off pad, and personnel decontamination.

• Methods for decontaminating and releasing equipment, materials, and packaged wastes from the site.

• Methods for housekeeping of on-site temporary facilities.

• Documentation on housekeeping and release limits for facilities, equipment, vehicles, and paved areas.

• Methods for verifying compliance with housekeeping and release limits.

• Seasonal shutdown procedures and requirements, if necessary

• Quantified fence line limits for airborne emissions of dust, beryllium, lead, and radionuclides in accordance with USACE Buffalo District air monitoring requirements.

• Methods for controlling airborne emissions of dust, beryllium, lead, and radionuclides during all site operations

• Methods for monitoring airborne emissions from the site for dust, beryllium, lead, and radionuclides.

The CCP will include a perimeter air monitoring plan (PAMP), which establishes procedures for measuring, documenting, and responding to potential airborne contaminants during the remedial action. The PAMP will focus on monitoring airborne contaminants at the site perimeter to protect against community exposure; this will complement personnel and work zone monitoring conducted to protect site workers (described in the APP/SSHP). The PAMP will provide monitoring procedures, response limits, action limits, and contingency measures to be taken if any constituent of interest breaches its limit. Details about action and response limits can be found in Section 5.1.7 The PAMP will include the following:

• A description of air-monitoring activities to be conducted using a combination of real-time (continuous and nearly instantaneous) instruments and the collection of air samples for laboratory analysis.

• Analytical methods and reporting requirements.

• Meteorological monitoring parameters, methods, and equipment.

• Pre-remediation baseline monitoring and sampling.

• QA/QC procedures.

• Data management, analysis, and reporting procedures.




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• Decision tree diagrams and/or tables that identify response limits, action limits, and contingency measures.

• A figure showing the locations of fixed monitoring stations, the meteorological station, and the construction site layout.

• Figures showing the locations of portable monitoring stations for each excavation area/work activity.

• Perimeter air-monitoring system layout and equipment.

4.1.5 Sampling and Analysis Plan

The SAP will adhere to Portage’s data QC requirements, the Uniform Federal Policy for Quality Assurance Project Plans, and UFGS Section 01 35 45.00 10. The SAP will describe field sampling procedures and how to submit samples for analysis. It will also cover field parameter measurement and data documentation, assessment, and reporting. The SAP will define Portage’s QC methods for collecting accurate, precise, representative, complete, legally defensible, and comparable data. The SAP will describe all parameter measurements for all matrices associated with the remediation.

The SAP will consider both original and innovative approaches to chemical/radiological parameter measurements to reduce costs and increase remediation efficiency. Portage will attain this through abbreviated sampling, contingency sampling and/or analysis, indicator or tracer analysis, on-site analytical services, equivalency, or screening methods. The SAP will identify laboratories. Portage will furnish copies of the USACE-accepted SAP to all laboratories and members of the field sampling crew. The SAP will provide enough detail about each level of investigation so it can be used as an audit guide for field and laboratory work.

Technical detail and direction for field personnel shall be provided through field sampling standard operating procedures, which are included in the SAP. These standard operating procedures provide comprehensive direction for performing all on-site sampling activities, such as sampling, performance of on-site and off-site instrumental parameter measurements, and data documentation.

4.1.6 Backfill and Restoration Plan

The BRP presents the means and methods for site restoration in accordance with the SOW. The plan identifies off-site fill sources, and final site grades. It describes the placement and machine compaction of backfill materials; placement and grading of topsoil and topsoil amendments; temporary and permanent seeding; and sedimentation and erosion controls after final grading and seeding. Backfill placement and grades shall optimize site drainage.




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4.1.7 Regulatory Compliance Plan

The RCP will outline the federal, state, and local regulations and guidance governing remediation activities at the site. Portage shall follow these requirements to ensure it protects human health and the environment.

4.1.8 Waste Management, Transportation, and Disposal Plan

The WMTDP will document the manner in which Portage will manage, transport, and dispose of excavated FUSRAP-contaminated soils/fill/debris from the time the waste is excavated/ processed until the disposal facility receives and accepts it. The plan describes the anticipated types and volumes of materials and the management practices Portage will use. The plan includes the following:

• Name, address, telephone number, and appropriate permit information for each licensed/permitted disposal facility plus the facility's requirements for accepting each waste stream, including its waste acceptance criteria.

• A letter from each accepting facility and its regulating authority acknowledging that it can accept the anticipated waste stream.

• Sampling, testing, and analytical requirements for each waste stream. • U.S. EPA identification numbers. • Waste minimization methods.

• Quantity of contaminated soils/fill and debris requiring shipment. • Waste transportation methods, routes, and vehicle flow patterns. • Name, address, telephone number, and appropriate permit information for each waste

transporter to be employed for waste shipment to the disposal facility. • Method of surveying the loading area and/or haul routes. • Methodologies for surveying transportation containers for contamination before

accepting them on-site, and again before shipping them off-site for disposal. • Demonstration that the proposed transportation mode is safe and cost-effective for waste

transportation.

• Methods used to prepare the waste transportation containers; leak and spill protection and prevention; and loading and transporting the waste.

• Methods used for staging the contaminated soils/fill; labeling, placarding, marking, and preparing the shipping documents; and any other requirements for transportation of waste to the licensed/permitted disposal facility.




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• Examples of shipping documents: a list of corresponding labels, packages, marks, and placards to be used for shipment and disposal facility advanced shipment notification forms, if required.

• USACE-accepted chain-of-custody form describing material to be shipped; includes certification that material is not radioactive, as defined in 49 Code of Federal Regulations (CFR) 173.

• How the waste transportation containers will be inspected before leaving the site.

• Format and description of the tracking system to be used while wastes are being transported.

• Waste preparation; packaging; loading and transport activities, including but not limited to physical, chemical, and radiological safety; environmental protection; and security.

• Techniques and equipment to be used to determine the weight of each shipment.

• A rigging plan for lifting more than 20,000 pounds.

• Plans for transportation spill response and coordination with local responders.

• Spill Prevention, Control, and Countermeasures Plan included as an attachment to the WMTDP.

• Emergency procedures for contacting USACE and regulators in case of spills, notices of violation, or other incidents. (Each transport vehicle shall have a contact number in case of emergency.)

• Plans for decontamination of the transportation equipment.

• Plans and procedures to ensure that operations do not result in further contamination of the site or communities through which the waste is transported.

• A treatment plan to fulfill RCRA obligations for any hazardous waste comingled with FUSRAP-related radioactive wastes.

4.1.9 Final Status Survey Plan

The FSSP will demonstrate compliance with radionuclide, beryllium, and lead soil cleanup requirements at the Luckey Site. Portage shall utilize protocols from the Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM).




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4.2 Procuring Equipment, Materials, and Specialty Services

Portage will order and schedule delivery of the required equipment and materials and subcontract services needed to complete the project. This includes developing and issuing purchase orders, negotiating and completing subcontractor agreements, and scheduling delivery of goods and services. Portage will perform as much of the subcontract work as possible on a firm-fixed-price basis and will obtain approval from the USACE KO before agreeing to any subcontracts exceeding a dollar threshold set by USACE.

4.3 Submittals

Portage will use the Submittal Register (Eng Form 4288) as shown in the QCP. Portage will transmit required submittals through the quality control system (QCS) and maintain a submittal record. The CQCP will specify how Portage will use the Resident Management System/QCS to manage these submittals through the three phases (preparatory, initial, and follow-up) outlined in the QCS. Typical submittals will include work plans, design packages, permit applications, discharge monitoring reports, and CQC submittals associated with the project’s definable features of work.

5. PHASE II – MOBILIZATION

The second project phase includes a number of field activities to be conducted before remediation activities begin. Portage plans to obtain limited authorization from the USACE to begin limited pre-remediation activities, after award of the mobilization task order, but before obtaining authorization to actually mobilize to the field. Specifically, this limited authorization will enable Portage to take care of preliminaries needed to begin/support field activities before having access to the field. Examples of such activities are personnel hiring and training (as discussed in Section 5.1.1), developing and implementing procurement plans/activities, and establishing subcontracts. Once USACE approves required work plans, the full NTP will allow Portage to mobilize to the site immediately. Figures 5-1, 5-2, 5-3, 5-4, 5-5, and 5-6 show the transition of AA, SZ, CRZ, and EZ boundaries through the mobilization phase to complete initial sampling, SZ construction, S1 sampling, S1 infrastructure installation, and final configuration. Portage specifically selected the locations of the stockpile and waste staging, handling, and processing areas in the S1 area to facilitate remediation of the entire site for the duration of the contract.

Mobilization activities will be focused in two areas:

• The area of the existing parking lot in the northwestern section of the site, which will become our AA/SZ, and the site perimeter, as discussed in Section 5.1.




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• The S1 area, which will contain our stockpile and waste handling and processing area, as discussed in Section 5.2.

The AA/SZ will be established within the existing parking lot in the northwestern section of the site. This approximately 400- by 300-ft area is where Portage will place support facilities, including office and laboratory trailers, parking, and material storage areas. Additional mobilization activities include establishing utilities, mobilizing and installing office and shower facilities and the on-site laboratory, and mobilizing remediation equipment. Before Portage accepts trailers and equipment on-site, they will be surveyed for radiation and beryllium, as described in the RPP and CCP.

Mobilization will not start until USACE has approved the APP/SSHP and the other work plans and all needed radiological and safety monitoring equipment is on-site and operational. The PM and site superintendent will direct mobilization. Portage’s SSHO and RSO will be present as needed to support the work. Portage expects that considerable local subcontracting, firm-fixed-price, will be done for services (such as fencing) and materials (such as road bedding) and will ensure that its approved safety protocols are followed.




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Figure 5-1. Site layout for support zone and administrative area preparation (characterization).




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Figure 5-2. Site layout for support zone and administrative area mobilization (construction).




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Figure 5-3. Site layout for S1 area preparation (characterization and soil treatment/excavation).




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Figure 5-4. Site layout for S1 area mobilization (construction).




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Figure 5-5. Final site plan, site-wide view (including perimeter air monitoring locations).




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Figure 5-6. Final site plan, detail view.




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5.1 Administrative Area and Support Zone Preparation and Mobilization

Initial mobilization efforts will focus on preparing the parking lot areas to support installation of support facilities and development of an AA and the SZ, supported by an initial civil survey of this area, and the S1 area (as practical). In addition, preparation activities will include work on the site perimeter to ensure that the entire site is secured. Sampling will be required first due to the lack of characterization data, and planned for the type of activities and/or future use. Characterization will consist of sample collection from soil borings consistent with the prescribed approach for final status surveys, to assess this area prior to commencing work, including for both worker exposure and potential subsequent cleanup of the area. Specifics associated with this sampling will be described in field sampling standard operating procedures included in the SAP.

Initially, Portage will manage work out of a temporary trailer until longer-term on-site facilities have been mobilized and installed. The priorities during this stage of mobilization will be to ensure that the AA and SZ are free of contamination, install utilities, secure site perimeter, establish beryllium control areas, initiate personnel exposure monitoring for beryllium, and initiate background air monitoring. Initial sampling will require that personnel have completed the beryllium lymphocyte proliferation testing (Be-LPT). The SZ, CRZ, and EZ boundaries for initial sampling and construction are shown in Figures 5-1 and 5-2.

This section describes these mobilization and site preparation activities, including the following:

• Personnel hiring and training.

• Signage and security.

• Clearing and grubbing.

• Fencing.

• Stormwater and sediment controls.

• Parking lots and roads.

• Installation and initiation of background air sampling.

• Facilities mobilization and installation.

• Utilities installation.

• Assessment and rehabilitation of west production well.

• Setup and certification of on-site laboratory.




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5.1.1 Personnel Hiring and Training

To support mobilization to the site immediately upon receipt of the NTP for mobilization, Portage will initiate hiring and training activities approximately two months before the anticipated NTP. This will leave enough time to conduct and receive results from the Be-LPT testing. Portage will identify all personnel who will perform work in support of mobilization, and evaluate them for beryllium sensitization. Based on Portage’s experience, results from the tests can take between six and eight weeks. Testing will also extend to certain subcontracted personnel (such as electrical workers) who will perform work that might expose them to beryllium. Once Portage has tested personnel and found them to not have beryllium sensitization, all required environmental, safety, health, and quality training will be verified and/or conducted.

5.1.2 Signage and Security

One of the first activities will be to construct/install signage and security infrastructure. First, Portage will install the required project identification sign (UFGS, Section 01 58 00) and additional signage needed to support on-site activities. One such sign will be a “Current Site Conditions” board, strategically located near the site entrance within the AA. This sign will consist of a 4- by 8-ft sheet of plywood mounted on 4- by 4-in. posts. A large image of the site will be attached to the plywood and covered with 0.25-in. Plexiglas. Using erasable markers, the SSHO and site superintendent will update this sign daily to illustrate changes that may affect site workers, vendors, and visitors. These changes may include, but are not limited to, general conditions, current hazards, traffic patterns, and PPE requirements. Reviewing the changes will be part of the daily toolbox safety meeting, during which site workers will be encouraged to ask questions, raise concerns, and assist in planning the day’s work.

Concurrent with signage installation, Portage will install equipment related to security. Portage will establish access controls to ensure only authorized personnel, including vendors, can access the site. To supplement fencing, Portage will install security gates at the Luckey Road main entrance; these will consist of two rigid gates with a chain-link fence cover. During nonworking hours, the fencing and gates will be the primary mechanism for controlling access to the site.

Portage will assign an individual to maintain security during working hours. Access to the site will be controlled with signs directing nonproject personnel to that individual for approval to access the site. All personnel will be required to sign in/out on the site access roster, and will be provided with an appropriate safety briefing. .

Portage will install closed-circuit cameras at the entrances to the site to address potential vandalism and thefts, such as those previously experienced at the site. The camera system will eventually extend to other strategic locations throughout the site, such as the excavation, ScanSortSM, and waste packaging areas. Access to feed from these cameras will be available to our project personnel and the USACE to support 24-hour surveillance of the site. The system




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uses H.264 video compression technology recording on a large 3-terabyte hard drive. It provides several weeks of continuous recording and can be further expanded with motion-activated recording.

Portage will continue to assess security during nonworking hours and make adjustments as necessary to maintain security, including evaluating the need for off-hours security coverage, if necessary.

5.1.3 Clearing and Grubbing

Clearing will consist of removing trees, brush, and vegetation that impede work at designated work areas. Air monitoring requirements for this activity and subsequent intrusive activities are described in the APP and CCP. Portage will clear and grub incrementally and only as needed within the designated working zones, minimizing disturbed areas and enabling the existing vegetation to help prevent soil erosion or windblown dust.

Areas to be cleared include the AA/SZ where trailers will be staged/installed, the parking lot, stockpile and waste processing area in S1, the east-west transportation corridor, and perimeter fence line. A 4,000-gal water truck will be on-site to apply water to the surfaces during all clearing and grubbing activities and to apply lignin sulfonate fixative to the final operating surface.

As required, vegetation will be cleared and grubbed along the perimeter fence of the site using primarily hand tools to provide access to make repairs to (or replace) fencing and/or to install perimeter air samplers and utilities. A skid steer with attachments may be used when necessary to assist with the installation of fencing, utilities, and other equipment and materials. When mechanical means are applied, water will be used for dust control. Vegetation debris will remain on-site and be used for best management stormwater controls. This will involve either using the debris as is or mulching/chipping it for use.

5.1.4 Fencing

Fence locations through mobilization and operations are shown in Appendix C. The 8-ft-high chain-link fence currently installed at the site boundary will remain in place. At the onset of mobilization, Portage will inspect this fence to assess its condition and identify gaps and/or areas requiring repair and/or replacement. If gaps are present in the existing chain-link fence, temporary fencing will be installed at the location of each gap.

As soon as practicable, but not later than 15 days after the date established for commencement of work, Portage will erect temporary safety fencing along open excavations. Portage will also install construction fencing around material storage/handling areas and/or mobile offices on the northwest side of the site (existing parking area), as reflected in Appendix C.




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Safety fencing will be a high-visibility, orange-colored, high-density polyethylene grid or approved equivalent, a minimum of 42 in. high, supported and tightly secured to steel posts located on maximum 10-ft centers. Safety fencing will be maintained during the project duration. The only expected excavation work during the performance of this part of the mobilization activity includes trenching for utilities, installation of posts for the air monitoring stations, and anchor installation for the trailers.

Construction fencing will consist of 6-ft-high chain-link mobile fence. Due to the duration of the project, chain-link fence posts will be constructed with portable concrete bases.

5.1.5 Stormwater and Sediment Controls

Stormwater and sediment controls are described in the SWPPP by project phase and area of site remediation. This activity will include installation of a perimeter silt fence around the S1 area and west of the AA bordering the west drainage ditch. This work will be performed in noncontaminated areas. After locating existing utilities, Portage will use a skid loader and attachments to trench, drive T-posts, and install a silt fence along the existing fence between the northeast paved area (SZ) and the S1 area. Portage will work with USACE to obtain permission to access the north side of the site, so the skid loader can be used for silt fence installation.

Some perimeter clearing and grubbing may be required before silt fence installation. In areas where physical features (i.e., existing swales and washes) make the efficiency of silt fencing questionable, straw wattles and/or erosion fabric may be used.

5.1.6 Parking Lot and Roads

Portage will construct temporary site access roads and transportation corridors with suitable grades and widths to ensure the safe operation of traffic at all times. Designated parking areas, walkways, and roads will be illuminated by either temporary installed lights fixed on poles or mobile lighting such as diesel-operated light plants to ensure the safety of workforce personnel and equipment during periods of limited visibility. Personnel walkways will be delineated, posted, and barricaded as necessary to separate operating equipment and the workforce as applicable.

Parking lot and road improvement/construction will consist of grading, watering, compacting, and placing crushed surfacing material where required. Existing pavement that becomes loose will be removed, stockpiled, and disposed of as appropriate. The east-west off-site transportation haul road will be 20 ft wide with a minimum turning radius of 60 ft. Based on a recent inspection and satellite images of the site, the existing parking area and east-west transport road will generally be suitable for use after clearing and grubbing. Portage anticipates, however, that some patching will be necessary (e.g., where trees/brush are removed), which could include the placement of base course into areas requiring repair, patching with asphalt, and/or laying chip




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seal over the surface in certain areas. Additionally, as reflected on the Phase 2 Parking and Transport Road drawing in Appendix C, areas along the east-west transport road will be built up with base course and/or crushed stone, and covered with asphalt, as necessary, to provide areas for installation of the truck scale (including approach areas) and a turnaround area. The actual extent of these efforts will be finalized after an engineering survey, when access to the site is possible to support this effort, and following the completion of clearing and grubbing activities in these areas.

Before construction starts, sampling of the road areas will be required due to the lack of characterization data (similar to the approach described in Section 5.1 for the parking lot). Portage will complete characterization through sample collection from soil borings consistent with the prescribed approach for final status surveys and will assess areas for both worker exposure and cleanup potential. Sampling specifics will be described in field sampling standard operating procedures included in the SAP.

5.1.7 Installation and Initiation of Background Air Sampling

Portage will install and operate background and on-site perimeter air samplers during mobilization to establish background and baseline levels for airborne constituents of interest (COIs), as detailed in the CCP (USACE 2016f) and summarized below. This activity will be a priority and will begin as soon as possible so that contaminated zone mobilization can begin. Both off-site background and on-site perimeter monitoring will continue for 90 days. The data collected will be combined with preliminary air limits to establish and enforce mobilization phase (limited intrusive) and remediation phase response and action limits at the work area and site perimeter. Air sampler locations, including the off-site background location, as well as the air monitoring requirements, objectives, and methods are defined in the CCP.

For on-site perimeter baseline air sampling, Portage will determine baseline concentrations of COIs by collecting samples at six perimeter locations equipped with low-volume air samplers and a continuous total suspended particulate (TSP) monitor.

Portage will use preliminary air limits and background and baseline air monitoring results to determine response limits and action limits. A response limit is a COI concentration that triggers contingent measures at the site (e.g., engineering controls or modified work practices). An action limit is a COI concentration that triggers a series of contingent measures or work stoppage. Portage will develop response and action limits in consultation with the Ohio Environmental Protection Agency (OEPA) and the USACE using the USEPA DQO process, considering factors such as sampling and analysis time for each monitoring method, associated precision and accuracy, and proximity of the sampler to the site boundary and off-site receptors.




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Portage will install a meteorological station with a solar panel and battery for remote operation during mobilization. The station will operate without line power supply, supporting uninterrupted operation of the station. The station is also designed with wireless capability for data uploading from a personal computer in the site office trailer. A field technician will maintain the station, but the site superintendent will have ultimate responsibility for data uploading and reporting.

Portage will maintain a field log book, measurement device calibration field forms, and monthly data listings. The site superintendent will prepare and submit weekly data summaries to USACE about the job site. These will include the maximum 15-minute average concentrations of TSP, average 15-minute wind speed, wind direction, relative humidity, air temperature, air monitoring station locations, and site activities. Monthly data will be provided to the USACE in an electronic format specified in the USACE-approved CCP. As desired by USACE, graphs, charts, and other data reports to document all meteorological and air monitoring data will be submitted.

5.1.8 Facilities Mobilization and Installation

After the SZ area has been cleared and secured, Portage will bring field trailers to the site to be used as its base of operations. The trailers are generally equipped with trailer frames and will be pulled to the job site by an on-road tractor. Once on-site, these trailers will be inspected, surveyed, and initially staged in an area of the parking lot that will not interfere with other ongoing activities. These trailers include (and will be located as shown in Figure 5-2):

• Four double-wide (64 by 24-ft) office trailers – three for our use and one for USACE’s use in the AA

• Three single-wide (64 by 12-ft) and one double-wide (64 by 14-ft) laboratory trailers – three in the SZ and one in the CRZ for sample preparation and transfer (see Figure 5-3)

• One double-wide (64 by 24-ft) break trailer in the AA

• One (44 by 12-ft) restroom trailer in the AA

• Two access control/shower (44 by 12-ft) trailers – into and out of the CRZ/SZ

• One (8 by 20-ft) Conex box with pedestrian doors at each end for use in the storage and management of IH instrumentation on the SZ/CRZ line

• Two (8 by 20-ft) Conex boxes with pedestrian doors at each end for access points at the EZ/CRZ lines (mobile access control).

As reflected in Figure 5-3, trailers will generally be on the north side of the AA and near/along the SZ/CRZ line. Double-wide trailers will require on-site assembly activities such as anchoring,




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installing skirts, and constructing permanent steps and landings. All trailers will be properly anchored and grounded before occupancy.

In addition, a steel-deck 120-ton-capacity truck scale will be brought to the site for weighing waste haul trucks before they leave the site. As shown in Figure 5-3, the truck scale will be installed near the western end of the east-west transportation access/haul road. Installation will include earthwork, concrete anchor installation, electrical power connection, and grounding.

5.1.9 Utilities Installation

Trailers will be connected to utilities brought on-site (e.g., telephone, internet, electrical, nonpotable water, and sewer connections), as appropriate. Temporary utilities will be used to support initial mobilization activities until permanent utilities are brought on-site. For example, port-a-potties provided and serviced by a local vendor will be placed on-site until trailers have been set and the sanitary sewer connected. Initially, generators will provide electrical power until permanent power is established, the first priority for the AA/SZ. Portage will provide bottled water for potable water and off-site water from a water truck for dust control until permanent water sources are available. The following sections detail utility installation based on Portage’s knowledge of utility availability/requirements to support planned remediation activities. Utility layouts are provided in Appendix C. These layouts will be further defined after completion of an engineering survey and utility location search.

Locating Existing Utilities. Before any ground-disturbing work, Portage will notify Ohio Utilities Protection Services (1-800-362-2764) about its excavation plans. Notifications will take place at least 48 hours but no more than 10 working days in advance (excluding weekend and legal holidays). No digging will be performed until the representative has visited the site and marked the underground utility location. Even though the underground utility location will be marked, Portage will use extreme caution when digging in those areas because its personnel have found through experience that the marking can be off from an actual line location by several feet.

Electrical. Toledo Edison will provide electrical power brought from the service line running parallel to Luckey Road. The Phase 2 Water and Utilities Plan drawing in Appendix C shows the proposed location of electrical transformers, service drops, and substation. Toledo Edison will distribute a three-phase service overhead, stepped down as required for specific applications. Portage has estimated total power requirements for the ScanSortSM system, water treatment system, trailers, dust suppression system, and lighting at approximately 700 kilowatts.

Establishing permanent power to site facilities will be phased in and prioritized to support the work schedule. Primary utility metering equipment will be near the site perimeter from Luckey Road to allow for on-site system work and rework to be performed by an electrical contractor with overhead utility capabilities. The first priority will be to provide security cameras and




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power for the perimeter air monitors, so the 90-day background monitoring can begin as quickly as possible. Compliant with applicable electrical code, the conduit will be hung on the perimeter fence to facilitate monitoring installation and startup. Then electrical lines will be installed in the support area to service trailers and area lighting. Finally, permanent electrical power to support lighting along the east-west transportation access road and for the soil sorter, dust control equipment, and water treatment system located in the S1 area will be installed. Setting of electric poles will involve close coordination and oversight by our SSHO and RSO.

Water. Water will be required to support activities such as dust control in the excavation and soil sorter areas, for personnel showers, and in the on-site laboratory. Estimated water needs will be approximately 41,470 gal/day. Peak usage has been estimated at 122 gallons per minute (gpm). Part of the dust control demand can be met using treated water from our contaminated water collection and treatment system which, under average conditions, will process about 9,750 gal/day (25 gpm) about 20 days per month. Peak water demands are not likely to occur concurrently, assuming that showering occurs at the end of shifts when earth work and soil movement will not occur. The on-site laboratory has special water needs and will be supplied with distilled and deionized water.

To meet potable water needs and also augment the contaminated water treatment system output, Portage will rehabilitate the west production well. Currently, the well is enclosed in a brick building. A tar patch on the roof may provide access, or alternative entry will be assessed during sampling of surrounding paved areas. This will be evaluated once access to the facility is viable during mobilization, and further details will be provided to USACE for review. Nevertheless, it is anticipated that, once accessed, the well can be rehabilitated and productive by disinfecting it and installing a submersible 100-gpm pump and approximately 320 ft of 2.5-in. galvanized pipe.

The well water treatment system will include three 200-gal pressure tanks to maintain pressure between 40 and 60 psi. Most of the well water (87 gpm) will be piped to project operations, as reflected in the utility drawings contained within Appendix C. Potable water (3 gpm) will be treated initially through a water softener followed by a reverse osmosis system. The reverse osmosis system will remove any beryllium, lead, radionuclides, and other metals present in the well above water quality standards. This will be confirmed by periodic sampling and analysis of both untreated and treated water from the well. The system will be housed in a heated Conex box.

The water will be sampled and analyzed for domestic supply parameters required by the ODH, listed at: http://www.odh.ohio.gov/odhprograms/eh/water/PrivateWaterSystems/quality.aspx, at the frequencies specified therein. This will include analysis for the following:

• Total coliform, E. coli, nitrate, giardia, cryptosporidium.

http://www.odh.ohio.gov/odhprograms/eh/water/PrivateWaterSystems/quality.aspx




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• Inorganics, including antimony, arsenic, asbestos, barium, beryllium bromide, cadmium, calcium, chloride, chromium (total), copper, cyanide, fluoride, hydrogen sulfide, iron, lead, magnesium, manganese, mercury, nitrate, potassium, selenium, sodium, strontium, sulfate, and thallium.

• Organics, including VOCs and SVOCs.

• Radionuclides, including alpha particles, beta particles, photon emitters, radium-226 and radium-228 (combined), radon, and uranium.

• Hardness, pH, specific conductivity, tannins, total alkalinity, total dissolved solids, total suspended solids, and turbidity.

Sewer. Sanitary sewer service to support the trailer complex will be brought to the site through a connection to the Village of Luckey sewer line. During mobilization, Portage will work closely with the Village of Luckey to establish a connection point, and then to run a line from this installation point to the AA/SZ along Luckey Road. Connections will be made to specific office trailers, one lab trailer, the restroom trailer, the break trailer, and the shower trailers, with anticipated sewer line locations as reflected in the Phase 2 Water and Utilities Plan drawing in Appendix C.

Telephone and Internet. Local service providers will provide/install telephone and high-speed internet service to each trailer, installed from the power poles to the west of the support area.

5.1.10 Setup and Accreditation of On-Site Laboratory

ARS and our project chemist will set up and operate the accredited on-site laboratory. ARS will operate the Luckey on-site laboratory under its previously approved quality system, thereby facilitating rapid laboratory accreditation at the project start based on its current accreditations and approved quality program.

ARS’s current accreditations will reduce the 10- to 12-month process necessary to accredit a laboratory that does not possess U.S. Department of Defense (DoD) Environmental Laboratory Accreditation Program and American Industrial Hygiene Association accreditations and support the schedule.

The on-site facility shown in Figure 5-3 will consist of four trailers equipped to conduct sample management operations and a variety of radiological and nonradiological analyses. The capacity and elements of the laboratory may be modified based upon project phase and task order requirements. One trailer will be located just inside the CRZ and will serve as the sample receiving and prep trailer. It will be connected to one of the trailers located in the SZ that will house the analytical equipment. It will contain a negative pressure hood with HEPA ventilation




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for direct handling of sample media for preparation for both on-site and off-site analysis. Once samples are prepared, they will be released from the hood EZ into the trailer CRZ.

Samples from the EZ working areas will be received at the sample receiving and preparation trailer located within the CRZ. Employees working in this facility will fully comply with the PPE requirements of the CBDPP and will exit the CRZ through the shower facility. Air monitoring requirements for this activity are described in the APP and CCP. Samples will be screened for radioactive contamination, checked into the Laboratory Information Management System, assigned a unique identification number, and labeled. A barcode system will be utilized in conjunction with the internal chain of custody to track all sample aliquots from sample receipt through disposal.

The instrumentation will include, but not be limited to:

• High-purity germanium gamma spectroscopy system(s) for radiological parameters Ra-226, Th-230, U-234, and U-238.

• Alpha spectroscopy system to provide isotopic analysis of uranium, thorium, and Ra-226 levels in soil and wastes.

• Low-background gas flow proportional counter(s) to process swipes/smears generated during the day-to-day site radiological control requirements.

• Inductively coupled plasma mass spectroscopy to analyze beryllium, lead, and any other required metals for industrial hygiene, waste, air, and water regulations.

• Two gas chromatography/mass spectrometry systems (one for volatile organics, one for semi-volatile organics).

• Instrumentation and equipment necessary to conduct wet chemistry processes to meet Ohio Water Quality Standards and National Pollutant Discharge Elimination System (NPDES) requirements.

During mobilization, setup, and startup of the on-site laboratory, samples collected from background and perimeter air monitors will be shipped to the ARS DoD Environmental Laboratory Accreditation Program and American Industrial Hygiene Association-accredited laboratory in Port Allen, Louisiana, for analysis. Once the on-site laboratory has been accredited, samples will be analyzed in the on-site laboratory.

The on-site laboratory may work a split shift schedule to ensure that all results are reported in a timely manner, and no project operations are delayed due to lack of laboratory results. A comprehensive data review process will ensure that all data delivered meet Portage’s high quality standard. Portage will use checklists for data review, which requires input from the entire




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workforce involved with sample handling, analysis, data reduction, and final reporting. Data will be reported according to contract requirements.

5.2 S1 Area Preparation and Mobilization

As the AA/SZ prep and mobilization nears completion, Portage will bring remediation equipment (e.g., the soil sorter, conveyor system, and the water treatment system, followed by the heavy equipment) to the site as space in the SZ becomes available. At the same time, Portage will prepare the S1 area for installation of the waste handling and processing equipment. Portage anticipates this will begin about four months after the start of on-site mobilization; it should take about three months to complete. Figures 5-3 and 5-4 show the AA, SZ, CRZ, and EZ boundaries through the S1 characterization/remediation/treatment and construction.

Some of the equipment proposed for remediation activities, such as the soil sorter and associated conveyors, will arrive disassembled. Portage will inspect the components when they arrive, survey them for any contamination, and stage them in the SZ for later assembly. Near the end of the mobilization task order, excavator, loaders, articulated trucks, water trucks, and the soil sorter reach stacker will be mobilized. Heavy equipment will typically be transported by a tractor pulling a low-boy trailer. Portage will conduct initial radiological and beryllium surveys of the equipment upon its arrival, and then work crews familiar with the equipment will reassemble it on-site.

Based on the site setup, an area of approximately 4 acres will be needed to support the ScanSortSM system and the associated conveyors, feed piles, product stockpiles, waste container handling and load-out, and soil place-back storage piles. Figures 5-5 and 5-6 show the proposed layout of the CRZ/EZ in the S1 area and the stockpile area, and the main waste handling and processing area. The S1 area provides a large enough area to accommodate the waste handling systems and to support the long-term needs for remediation of the site. The overall layout will be developed to optimize work flow of equipment, personnel, and waste movement across the site. By strategically locating the waste processing area in the S1 (least contaminated area) the production rates may be adjusted throughout the project as necessary. If the project is funded at a higher level, for example, there will be enough flexibility to shift to other areas of the site with higher contaminated soil volumes without having to relocate the waste handling systems.

Before any activities within the S1 area, Portage will conduct further civil survey work necessary for the activities to be performed in this area. Additionally, Portage will perform sampling before field activities due to the lack of characterization data. This sampling will involve collecting soil borings consistent with the prescribed approach for final status surveys to assess the area before work commences; it will include both worker exposure and potential subsequent cleanup of the area. Specifics associated with this sampling will be described in field sampling standard operating procedures included in the SAP.




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Portage will install high-visibility fencing around the planned work area per Section 3.4.1.2 of UFGS, Section 02 61 13. After erecting fences and posts, Portage will install stormwater and sediment controls per Sections 1.3.2 through 1.3.5 of UFGS, Section 02 61 13. These will include silt fencing, straw wattles, berms, ditches, and channels designed to keep run-on water from entering the planned active work area and runoff water from leaving. Locations are described in the site SWPPP and based on the detailed civil survey and resulting topographical map. After installing sediment/water controls, Portage will use a brush hog to mow a 245,000-ft2 area to prepare the operating area (CRZ, EZ area of S1). Because some of this work requires ground disturbance, it will not begin until perimeter air monitoring has been performed for the required minimum of 90 days to establish a background level baseline.

5.2.1 Treating and Excavating Contaminated Soil from S1

After the area has been cleared and the fence and sediment controls installed, Portage will sample selective contamination areas within the S1 facility footprint to determine nature and extent. Previous sampling in the S1 area has indicated areas with lead contamination in the western two-thirds of the S1 footprint. Sampling will confirm these results and determine the volume of contaminated material. These data will support removing these pockets of contaminated soil to allow the area to be down-posted to support planned preparation and construction activities for the soil sorter and the waste handling infrastructure shown in Figure 5-6. This down-posting will support performance of infrastructure construction activities while minimizing exposure to construction personnel to the greatest extent practical. Before excavation of lead hot spots, the area will be treated in situ using an OEPA-demonstrated product, which chemically stabilizes lead-contaminated soil and minimizes lead leachability. EnviroBlend® (or equivalent) will be added in liquid form to the contaminated soil and mixed thoroughly, after which treatment confirmation sampling will be performed (TCLP testing). If it is found, after initial stabilization efforts, but prior to excavation, that the soil still contains lead at levels above those that would require LDR requirements, additional EnviroBlend® would be added to the in-place soil to further stabilize the lead, and additional verification will be performed. This process will continue, prior to the soils being excavated, until analysis demonstrates that the soil no longer exceeds TCLP. Upon passing TCLP testing for soluble lead, the contaminated soil will be excavated. Based upon the volume of the contaminated soil in these hot spots, Portage will either package the material for disposition or place it in waste stockpiles in accordance with UFGS Section 02 61 13, Excavation and Handling of Contaminated Material. Although the volume of soil removed through this effort could be as high as 540 cubic yards (CY), based on the modeled extent of contamination provided in the SOW, Portage believes that with the approach defined above, the final quantity will be substantially less, therefore generally supporting packaging at that time.




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Because the eastern one-third of S1 has deeper areas of contamination, this area will be left undisturbed and covered with gravel if optional 5,000-CY place-back stockpiles are needed, as shown in Figure 5-6.

Work will be carefully planned with USACE and Portage’s SSHO and RSO before this intrusive work begins. All training will be completed, and all work controls will be in place before intrusive work starts; all work will be conducted in Level C PPE with high-efficiency powered air-purifying respirators. In the areas where contamination is removed, Portage will conduct radiological, beryllium, and lead surveys and sampling to demonstrate the area is clean and ready for down-posting in accordance with the CCP and FSSP. Analytical results will be reported to USACE to support downgrading the area to an SZ to facilitate planned construction activities in S1. Following USACE approval, Portage will install temporary construction fencing to delineate this area as an SZ. Infrastructure installation will begin once the S1 area has been established as an SZ.

5.2.2 S1 Infrastructure Installation

After USACE has approved downgrading the S1 area to an SZ, Portage will prepare the area for construction of infrastructure for the soil processing equipment and other associated facilities. Many of the features discussed below are shown in Figure 5-6. Stormwater management controls associated with these structures are discussed in the SWPPP.

Geomembrane and Grading Gravel Cover. In the nonFUSRAP waste stockpile and ScanSortSM feed stockpile areas, Portage will place a geomembrane and gravel cover over remediated or clean soils. In contrast, the east side of S1 contains deeper pockets of contaminated soils that will not be remediated as part of the S1 area preparation. If the two easternmost 5,000-CY place-back stockpiles are necessary, a gravel cover will serve as a barrier between the underlying contaminated soils and place-back soils. It should be noted that these two easternmost 5,000-CY stockpiles are based on quantities of place-back soil that Portage has projected would be generated through the remediation of Trenches 1 and 2. If remediation were to start elsewhere, such as in Lagoon A, these stockpiles might not be needed. As such, Figure 5-6 reflects these stockpiles as being optional. A cross section of the optional 5,000-CY stockpiles is provided in Figure 5-7.

The northern place-back stockpile will not have a gravel or geomembrane base since it will be placed on an area cleared through FSS sampling. Because the material in the stockpile is clean, no berm will be necessary as well, but the pile will be surrounded with silt fence. A drawing has been included in Appendix C providing a general geomembrane plan. Geomembrane specifications will be provided in manufacturer literature, which will be provided to the USACE after a vendor has been selected.




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Foundations/Pads. After installing a gravel base, Portage will install concrete foundations/pads for the soil sorter, the decontamination pad, and the 100-CY stockpile area. Project personnel will perform excavation and form work for construction of these foundations/pads by preparing the area so that the concrete vendor can park near the foundation/pad location and pour the concrete. Plan and profile views of a typical 100-CY stockpile pad are provided in Figure 5-8. As reflected in the Concrete Pad drawings in Appendix C, the 100-CY stockpiles will be located on a single 110- by 140-ft pad that drains to the southeast, for collection in a drain that feeds to the water treatment system to the southeast.

Decontamination Pad. Portage will construct a concrete decontamination pad with a sump and containment berm at the EZ/CRZ boundary. This pad will be sized for a 75-ton reach stacker, which is the largest anticipated piece of equipment that may require decontamination. The pad will be 50 by 75 ft (3,750 ft2) with a sump and containment berm and will be sloped to drain to the northwest and collect in a trench drain. The pad will be underlain by an extended area of base course materials. A crushed stone base course will be compacted to a minimum thickness of 12 in. A bedding sand layer will be placed and a geomembrane along with a double-sided geocomposite drainage net installed. The pad will consist of an 8-in.-thick, wire fabric and/or rebar-reinforced concrete. A 12- by 12-in. concrete berm will surround the pad. A Kohler diesel-powered pressure washer (or equivalent) that heats up to 140°F water temperature and supplies more than 3,500 psi will be staged at the pad along with a vacuum cleaner and assorted brooms, wipes, and brushes. Additional details are provided in the Concrete Pad drawings in Appendix C.

ScanSortSM Facility and Pad. Although ScanSortSM does not specifically require a pad to operate on, past experience shows that material occasionally falls off the conveyors, requiring periodic cleanup of the area around the sorter. To address radiological and beryllium concerns, a pad under the sorter will provide for efficient cleaning of the area, thereby minimizing dust generation. Installation of the ScanSortSM will include the construction of a 30- by 45-ft (1,200-ft2), clear-span, rigid-frame, 26-ga. roof/siding, uninsulated, pre-engineered, open-air metal building to house the ScanSortSM. The floor will be concrete with floor drains/trench system and piping connected to the adjacent water treatment plant (Figure 5-2). The area for site preparation (clearing/grubbing and installation of base material) is approximately 50 by 100 ft (5,000 ft2). One hundred thirty-three square feet of base course 1 1/2 in. minus stone base will be compacted to 12 in. deep. Building footings and a 6-in. concrete slab will be poured. The ScanSortSM floor will be concrete with floor drains/trench system and piping connecting to the adjacent water treatment plant (Figure 5-1). The pad will accommodate the Butler building that will be built over the ScanSortSM system. Specifications for the facility and pad are provided in Appendix C.




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Figure 5-7. Typical place-back stockpile cross section for optional eastern stockpiles.




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Figure 5-8. Plan and profile views of a typical 100-CY stockpile pad.




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Stockpiles. Stockpile areas within the EZ will be constructed of concrete or gravel underlain by a geomembrane liner base, sloped to allow leachate collection. They will have perimeter berms to prevent run-on and runoff. Stockpile height will be limited to 15 ft. Samples from beneath each stockpile area will be collected before construction of and after removal of the stockpile at a frequency of one per 500 ft2 from 0 to 0.5 ft and analyzed for FUSRAP and chemical contaminants identified in UFGS, Section 02 61 13, Table 2.2-2.

Stockpile bays will be constructed at the input and discharge locations associated with the soil sorter with concrete floors and ecology block sidewalls, and will store 365 CY of potentially contaminated soil before placement in the sorter (at the input side) and 100 CY of nonradiologically contaminated soil at the ScanSortSM system discharge. Stockpile bays allow for material to be handled with heavy equipment while minimizing the potential of material being transferred to the surrounding areas. Concrete and ecology block construction of the bays will allow the areas to be washed down or gross decontaminated between placements of material. The stockpile bays will be constructed so that water used for bulk decontamination will drain to a sump, where it will be collected for treatment (Figure 5-6).

5.2.3 S1 Waste Processing Equipment and Facility Installation

After the S1 infrastructure (pads, utilities, and ground cover) is in place, Portage will assemble the waste processing equipment and construct the waste handling and processing facilities. The waste processing equipment, having been mobilized to the site in the early part of the mobilization phase and staged in the SZ, will be moved to the S1 area, where it will be assembled and connected to utilities, as required, to support startup.

ScanSortSM, Butler Building, and Conveyor System. After the concrete slab has cured, the ScanSortSM equipment will be transported to the soil sorting area and placed on the pad using a crane, excavator, or other suitable equipment. Components to be installed include the ScanSortSM system, the power distribution system, supporting conveyors, extruder trommel, and infrastructure needed to support safe operations and control of airborne contaminants. Details of the layout of the ScanSortSM system, including associated equipment, are provided in the soil sorting operations plan (SSOP) included as Attachment 1.

Following installation of the ScanSortSM components, a Butler building with open-air ventilation will be constructed to house the sorter and feed hoppers and portions of the output conveyors. The 30- by 45-ft (1,350-ft2) clear span rigid frame, 26-gauge roof/siding, uninsulated preengineered metal building will protect the sorter from the elements. Portage’s work crews will assemble the building in place. Power and water will be connected after the building is constructed and the sorter assembled.




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The conveyor system, including radial stackers, will be installed extending from the ScanSortSM equipment to the stockpile locations. The conveyors and stackers will be of the mobile type supported by tires and axles to allow adjustments during operations. The mobile-type conveyors are not designed to be anchored; therefore, no concrete or soil anchors will be used. The conveyors do require a relatively level and solid operating surface. The operating location will be graded, and a compacted layer of soil/gravel material will be placed over the natural soil to provide a solid working surface. Concrete pads are planned for construction under the ScanSortSM and initial conveyor as well as the stockpile locations. The pads will provide a smoother surface for removing any material that might accumulate under the conveyor system. The radial stackers will be of the mobile type with axles and wheels capable of stacking within a minimum arc of 270 degrees. A telescoping stacker will allow multiple arcs of stockpiles to be created using the same radial stacker, and vertical angle adjustment capabilities will provide for adjustable stockpile heights and more control over material free fall dust during stacking operations.

Dust Control System Installation. An air-atomizing nozzle technology, Dry Fog™, will be used to control dust at multiple material transfer points. This technology not only controls beryllium dust without the water addition typical of standard misters but also suppresses the <10 micron fine beryllium particles that are anticipated during soil processing. Once the ScanSortSM system has been installed, the Dry Fog™ system components will be installed at all ScanSortSM conveyer material transfer points, input trommel, and waste container loading platforms.

5.2.4 Water Management and Effluent Monitoring

Based upon the estimated quantities of contaminated water that may be produced by seepage into open excavations, precipitation onto open excavations or bermed soil stockpile areas, and by decontamination of equipment and dust control, a water treatment plant will be procured and installed during mobilization to treat contaminated water before on-site reuse or discharge.

The 100-CY stockpile area, the decontamination pad, and ScanSortSM facility will each have concrete pads that will be sloped to direct water to drains at a corner/end of the pad. From there, the water will flow by gravity through underground piping to an underground collection tank to the northeast of the water treatment system. This 10-ft by 10-ft by 13-ft-deep concrete vault/pit is designed to hold approximately 5,000 gallons of wastewater. A 600 gpm sump pump will pump the collected water into a wastewater treatment system storage tank. These facilities are defined further in Appendix C. Water that accumulates in other areas, such as excavations, bermed stockpiles, container loading and staging areas, etc. (including stormwater, groundwater) will be removed using hoses, transfer pumps, and the dirty water truck at the direction of the site superintendent, and trucked or transferred using hoses to the wastewater storage area.




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The system will include removal, discharge, and transport of contaminated and treated water by separate tank trucks; separate storage of contaminated and treated water; treatment of contaminated water; and on-site reuse or disposal of treated water. According to U.S. EPA, the best available control technology for removing radionuclides, beryllium, and other metals is reverse osmosis (RO). The WMP provides details about the on-site water treatment system.

The treatment system will be skid-mounted and mobile. The storage tanks will be wheeled over-the-road Baker tanks. Portage field engineers and technicians and vendor representatives will install the system at the location shown in Figure 5-6 and will connect power and piping. The system will be transported to the S1 area using a crane, excavator, or other suitable equipment and installed in a heated Conex for all-weather operation. The system is designed to process water at 25 gpm, with sufficient treatment and storage capacity to manage seepage and stormwater under average conditions and capacity to accommodate 25-year, 24-hour storm events. The system has the capability to operate in batch or continuously without operator attendance, with performance monitored and controlled through a programmable logic controller with high-limit alarms and automatic shutoff and wireless emergency notification. Storage tanks will be brought on-site or demobilized as needed to accommodate flows greater or less than predicted.

Treatment of VOCs and SVOCs will not be required based on results of surface water and groundwater sampling during the RI. If initial sampling indicates that VOCs and SVOCs are present in contaminated water, a carbon treatment will be added as a final polishing step. RO reject water will be added to the influent tank or eventually discharged in accordance with the WMP, after testing and notification to USACE. If secondary liquid wastes are determined not to meet the Village of Luckey discharge criteria, then the liquid wastes will be disposed of off-site as industrial waste at the Veolia facility in West Carrolton, Ohio. Solids collected in the clarifier and spent cartridge filters will be added to solid wastes for off-site disposal.

Under average conditions the contaminated water from all sources will be treated and reused on-site, for dust control and equipment decontamination or during compaction of backfill or hydroseeding. Discharge of treated water to the NPDES permitted outfall would occur only in the event of seepage or precipitation significantly above average conditions for the Luckey Site, such as a 25-year/24-hour storm event. The USACE will be notified and analytical data for the effluent will be submitted five days before the first discharge to the permitted outfall. The USACE will be notified and analytical data will be submitted for subsequent discharges; however, the five-day waiting period will not apply.

5.2.5 Final Exclusion Zone Setup

An EZ will be established for the remediation operations, surrounded by a CRZ to ensure that contaminants are contained within the project site. Both the EZ and CRZ will be posted with




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appropriate signage. The final EZ setup will include installing fencing that delineates the zone and placing a Conex box for access into and out of the zone. Portage has used this concept for worker donning, doffing, and screening, and the box can be moved by equipment on-site to accommodate operations.

Container loading/survey racks within the EZ will be located adjacent to the south EZ/CRZ boundary. Container racks will house intermodal waste shipping containers during waste loading and survey/decontamination activities.

Industrial hygiene and environmental monitoring equipment will be located at the EZ and CRZ boundaries and additional industrial hygiene monitoring equipment at locations where personnel may be exposed to COCs and/or radiological contamination.

5.3 Site Layout

This subsection describes the location, layout, and function of temporary on-site facilities and planned work areas for the project, as depicted in Figures 5-5 and 5-6.

5.3.1 Parking and Site Access

General access to the site will be through an entry to be installed a couple of hundred feet north of the current site entrance off of Luckey Road. This entry will be for general vehicle traffic, including deliveries of materials. A parking area will be established in the AA just inside of this entry point. In addition to fencing, Portage will install security gates at the Luckey Road main entrance consisting of two rigid gates with chain-link fence cover. The current site entrance will be used as the access road for off-site transportation vehicles (e.g., for the transport of waste off-site for disposal). This access will be similarly controlled with fencing and gates, and will be maintained by site personnel during times of vehicle use.

5.3.2 Traffic Flow

General traffic into and out of the site will be through an access point leading into what is the current parking lot, as identified in Figure 5-6.

Access for waste transportation vehicles will be provided through the use of the current east-west road. This haul road will be 20 ft wide with a minimum turning radius of 60 ft.

Temporary site access roads and transportation corridors will be constructed with suitable grades and widths to ensure the safe operation of traffic at all times. Designated parking area, walkways, and roads will be illuminated by either temporary installed lights fixed on poles or mobile lighting such as diesel-operated light plants to ensure the safety of workforce personnel and




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equipment during periods of limited visibility. Personnel walkways will be delineated, posted, and barricaded as necessary to separate operating equipment from the workforce as applicable.

5.3.3 Support Trailers and Facilities

The support trailer compound is located in the northwestern portion of the site with access via an access road to be constructed just to the north of the current access point on Luckey Road. Trailers will be connected to utilities brought on-site (e.g., telephone, internet, electrical, nonpotable water, and sewer connections). The office trailer compounds and support facilities will be maintained for the duration of remediation through site restoration and will be modified as required to meet the support requirements of the project.

5.3.4 Waste Staging Area

A waste transportation staging area is located just to the south of the ScanSortSM system and north of the east-west transportation corridor, as depicted in Figure 5-6. A quantity of empty containers will be staged on-site to ensure that no interruption occurs to the continuous flow of the off-site disposal process. Filled containers will also be stored in this area, awaiting removal. Containers will arrive on separate chassis and placed in the storage area with a reach stacker for moving the containers off the trucks; and between the staging area, which is within the CRZ; and into the EZ, where they are filled.

5.3.5 Water Treatment Facility

The water treatment facility is located in the southeast portion of the S1 area, as shown in Figure 5-6. The treatment system will be skid-mounted and mobile. The storage tanks will be wheeled over-the-road Baker tanks. A detailed description of the water treatment facility is provided in the WMP.

5.3.6 Material and Equipment Storage Yard

A material and equipment storage yard will be established in the western portion of the site (see Figure 5-6) in the south corner of the SZ, on top of the existing parking lot. This storage yard will be used for the storage of equipment and materials entering or leaving the site through the adjacent entry point. A temporary entry control point will be established on the eastern side of this yard for controlled movement of equipment and material into and out of the CRZ.

5.3.7 Decontamination Facilities

Equipment that has become contaminated or is potentially contaminated will undergo gross decontamination at the exit point from the trench area. This process uses a high-pressure fire hose or water cannon from the water truck to remove visible clumps of mud and dirt and reduces




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the loading on the decontamination pad. The water will be directed into the excavation, where it will be managed consistent with other excavation water. The piece of equipment is then moved to the decontamination pad through the EZ. The exception will be at the completion of a remediation area ready for FSS and at the end of project. At these times, temporary decontamination areas lined and bermed with geomembrane will be used for gross decontamination before transfer to the decontamination pad.

As shown in Figure 5-6, the decontamination pad will be constructed of concrete, with a sump and containment berm at the western edge of the EZ/CRZ boundary to be used as the soil processing area. This pad has been sized for a 75-ton reach stacker, which is the largest anticipated piece of equipment that may require decontamination. A 12 by 12-in. concrete berm will surround the pad. A pressure washer that heats up to 140°F water temperature and supplies more than 3,500 psi will be staged at the pad along with a vacuum cleaner and assorted brooms, wipes, and brushes. Water will be pumped from the sump and processed through the on-site water treatment system described in the WMP. Sediment will be placed into EZ 365-CY ScanSortSM feed stockpiles.

5.3.8 Contamination Zones

Areas surrounding the excavation zones will be designated as EZs. EZs on this site consist of active excavation areas, the soil loading location at each excavation area, the ScanSortSM operations (including feed and product conveyors), waste stockpile areas, the water treatment facility, the decontamination pad, and truck/personnel pathways between these areas. The areas where personnel and equipment leave the EZ will be designated as the CRZ. The EZs will be delineated by rad rope with proper signage. Entry to the EZs will be restricted to trained personnel under the control of Portage’s site superintendent, and authorized visitors accompanied by Portage’s SSHO, RSO, or site superintendent. Persons entering the EZ will be required to wear the specified PPE and abide by the APP/SSHP, CBDPP, and RPP, and applicable Radiation/Beryllium Work Permits. Exit from the EZ will be only through designated areas, in accordance with contamination reduction procedures. However, the EZ boundaries may be adjusted based on changes in field conditions or equipment needs.

5.3.9 On-Site Laboratory

The on-site laboratory facility, shown in Figure 5-6, will consist of four trailers equipped to conduct sample management operations and a variety of radiological and nonradiological analyses. One trailer will be located just inside the CRZ and will serve as the sample receiving and prep trailer. It will be connected to one of the trailers located in the SZ that will house the analytical equipment.




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6. PHASE III – REMEDIATION

The following discussion is generic, and subsequent revisions of this document will address specific remediation areas as they are identified. The primary objective of the remediation project described herein is the timely and effective cleanup of the site in accordance with the Luckey Site Record of Decision for Soils Operable Unit, Final (USACE 2006). The selected remedial alternative provides for the excavation of impacted soils, both on-site and off-site, and those adjacent to the site where contamination has migrated through natural means, to achieve cleanup goals (Table 6-1) for unrestricted use by the critical group, which has been identified as the subsistence farmer for the Luckey Site (note: radionuclide cleanup goals represent concentrations above site background).

Table 6-1. FUSRAP cleanup goals. COC Cleanup Goal

Beryllium 131 mg/kg Lead 400 mg/kg

Ra-226 2.0 pCi/g Th-230 5.8 pCi/g U-234 26 pCi/g U-238 26 pCi/g

6.1 Preparation Exclusion Areas

Before start of excavation, the following preparation activities must be accomplished. Air monitoring requirements for these activities are described in the APP and CCP.

Preconstruction Survey. In addition to the site civil survey as part of Phase II mobilization, Portage will perform a survey specific to the excavation area. This survey will provide more detail for installation of stormwater and sediment control features; confirm existing grades (original ground) in the area; and demarcate the estimated excavation boundaries to the outside areas, including the perimeter boundary and facility structures. The survey data will be loaded into the excavation model for use in our Global Positioning System (GPS)-equipped excavator. Work will be performed in accordance with Section 3.1 of UFGS, Section 02 61 13, with oversight by the CQCSM.

Fencing and Signage. This phase of the project begins with installation of high-visibility fencing around the EZ enclosing the active work area and the haul road to the sorter. Posts, fencing, and signage will be installed in accordance with Section 3.4.1.2 of UFGS, Section 02 61 13. The excavation area and the haul road to the sorter will be designated as an EZ. The majority of the EZ will be encircled by a CRZ for support personnel, vehicles, and equipment. Fence installation will include adjacent areas of contamination as practicable for




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sequencing and pollution prevention. In addition to standard and required fencing and signage, Portage will build/install a “Current Site Conditions” board in the SZ near the change trailer. This sign will consist of a 4- by 8-ft sheet of plywood mounted on 4- by 4-in. posts. A large image of the site will be attached to the plywood and covered with 0.25-in. Plexiglas. Throughout the project, the SSHO and site superintendent will be responsible for updating this sign to note changes that may affect site workers.

Surface Water Sediment Controls. After the fencing, postings, and signage have been erected, stormwater and sediment controls will be installed as described in the SWPPP. These measures will include silt fencing, straw wattles, berms, inlet protection, and ditches and channels designed to keep run-on water from entering the EZ and runoff water from leaving. Installation locations will be as described in the site SWPPP and based on the detailed civil survey and resulting topographical map. In addition, as haul routes in the EZ are developed, corrugated metal pipe culverts will be installed in areas of high traffic so that ditches and channels will not require constant repair and rebuilding. This work will be performed using the skid loader with trencher and post driver attachments, and it will be supported by the front-end loader or excavator as necessary.

Clear and Grubbing. Following installation of the sediment/water controls, limited areas of the EZ will be cleared and grubbed as required in UFGS, Section 31 11 00, to allow access for excavation using a loader, excavator, and skid steer loader. As needed to perform the excavation, areas will be cleared and grubbed so as to take advantage of the erosion protection provided by existing vegetation. If necessary, chainsaws will be used to remove trees in the excavation area. In this case, workers will be trained on how to safely operate chainsaws and equipped with specific PPE, including chaps, ear and eye protection, and Kevlar gloves. Trunks, branches, and root balls will be managed and disposed of as specified in our approved WMTDP.

Dust Control Methods. A clean-water truck, along with a boom-mounted sprayer on the excavator, will be the primary means of controlling dust within the excavation area. The water truck will deliver treated water from the treatment plant or production well to the excavation area and travel and remain in the CRZ. It will be equipped with spray bars and a top-mounted water cannon to deliver dust-control water from extended distances across the CRZ boundary and into the EZ excavation area. The excavator will be equipped with a water storage tank mounted on the counterweight and a combination of hard piping and hose plumbed to the end of the boom and will be used to deliver a spray of clean water to the excavation face for targeted dust control. The spray will be controlled by the equipment operator from inside the cab. If conditions warrant, pedestal-mounted portable water cannons will be fed by the clean-water truck via canvas fire hose. These units can be moved to whichever area needs additional dust control, and are controlled remotely by the excavator operator.




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Dust Control using Air-Atomizing Nozzle Technology Dry Fog. During soil handling and sorting, there is potential to generate beryllium dust with particle sizes in the range of 1-10 microns. To manage beryllium dust during processing, air-atomizing nozzle technology will be used at multiple material transfer points. The system will address beryllium in the 1-10 micron particle size associated with the fine clays. The Dry Fog dust suppression system will use ultrasonic, air-atomizing nozzles, compressed air, and plain water to produce a dry fog (1-10 micron droplet size) that agglomerates to airborne dust particles (PM-10 and PM-2.5). The fog and dust agglomeration will increase the weight of the airborne particles at the source, causing the particles to fall back into the process.

6.2 Overall Excavation Approach

6.2.1 Deep Excavation Management

Per Occupational Safety and Health Administration (OSHA), excavations greater than 5 ft deep require benching, shoring, or layback to ensure the safety of workers who are required to enter the excavation. At the 18-ft depth, maximum anticipated for the site, a 2:1 slope will result in the top of the excavation being laid back 36 ft around the perimeter. The slope at the excavation face may be steeper to allow the excavator to reach the bottom, and personnel will not be allowed to approach any closer than 36 ft from the toe of the excavation face, a distance that represents the theoretical natural 2:1 angle of repose. The 36-ft line will move with the excavation, and it will be marked with signage and flagging when personnel are required to access the excavation. If excavations cannot be sloped as described above due to encroachment on property boundaries or structures, alternative protective systems such as benching, shielding, and shoring will be utilized, as described in the excavation/trenching plan in the APP. An OSHA-competent person will inspect deep excavations daily and after weather events to ensure continued OSHA compliance and worker safety.

Excavation will proceed as a vertical-slice operation where the excavator will pull excavated material from the bottom up the slope for load-out. This allows wetter materials (slimes) to be mixed at the bottom with dryer materials near the top so that moisture content can be managed for optimum load-out and processing.

Water management could become a concern in deeper excavations. As excavation proceeds to depth and groundwater develops in the excavation, we will utilize the GPS feature on the excavator to configure the bottom of the excavation to flow from the excavation sides to the middle of the excavation. A shallow secondary channel will be excavated lengthwise down the middle of the excavation and graded toward a sump at the far end of the excavation. The sump will be constructed and managed per specifications and the WMP. Water collected in the sump will be pumped to a dedicated water truck used to haul potentially contaminated groundwater from the excavation to the water treatment system.




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6.2.2 Excavation Control

To limit personnel exposure to radiological, chemical, and physical hazards, Portage will limit the number of personnel entering the EZ and excavations. To accomplish this, Portage will use a Trimble GCS900 Grade Control System GPS mounted on the excavator and teamed with a robotic total station to determine cuts and fills.

Civil survey data are entered into a data collector, from which digital models of the excavation are generated. The models are loaded into the GPS device in the excavator and the robotic total station. The models appear on the computer screen in the excavator cab and direct the operator to reach specified lines and grades. Identical information is available at the robotic total station for those situations where the excavator is unable to reach the point to be surveyed. Accuracy for this system is consistently +/- 0.1 ft, ensuring that excavation lines and grades are achieved and over-excavation is eliminated or greatly reduced. A model of expected contamination areas and depths can be loaded into the machine control unit. Existing core data from the excavation area will be loaded into the model to assist in identifying areas of especially high contamination, in particular beryllium and lead contamination. Further, machine control will be used when placing backfill to ensure that clean import fill is placed to the required level before place-back soils are introduced in the excavation.

6.2.3 Material Handling Equipment

A Komatsu PC300 (or equivalent) extended-reach excavator with 2.5-CY bucket and hydraulic thumb, capable of removing material from the bottom of a 20-ft excavation, will be used. Equipment operators and drivers working in the EZ will be in Level C PPE with high-efficiency powered air-purifying respirators. Operationally, the excavator will be equipped with a water storage tank mounted on the counterweight and a combination of hard piping and hose, plumbed to the end of the boom and used to deliver a spray of clean water to the excavation face for targeted dust control. The spray is controlled by the operator from inside the cab. This excavator will also be plumbed hydraulically for a quick-change shear/processor unit that will be used to size-reduce debris as required. The versatility of this machine will reduce the number of pieces of equipment operating in the EZ and, in doing so, will increase the margin of safety for pedestrian personnel and decrease the level of effort associated with equipment decontamination.

The PC300 excavator will be equipped with GPS machine control, which uses mechanical and software components to guide the operator during excavation to ensure that lines and grades are met and that over-excavation is eliminated.

Soil excavated by the PC300 excavator will be direct-loaded into the articulated haul truck whenever possible. If terrain or other site conditions preclude direct loading, the excavator will side-cast material where the loader has best access. The loader will pick up the material and load it into the articulated truck for transport to the ScanSortSM feed stockpiles (365-CY piles) shown in Figure 5-6.




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6.3 Material Sorting and Processing

6.3.1 Waste Types and Disposal

Assuming that ODH will work with USACE to classify the radioactive component of the Luckey soil as TENORM, a “source based” waste disposition strategy is allowed under the State’s recently promulgated regulations [Ohio Revised Code (ORC) 3734.02(P)(2), ORC 3748, and OAC 3701] for landfill disposal and exemptions of TENORM-contaminated material. Based upon this assumption, the treatment and disposal needs may include Subtitle D landfill, Subtitle C landfill, TSDF (soil treatment for lead), and FUSRAP-related TENORM waste. Based upon their proximity to the site, the Waste Management Northwood, Ohio, and US Ecology Inc. (USEI) Wayne, Michigan, facilities represent the most cost-effective options. The USEI, Grandview, Idaho, facility is listed as an option if materials with higher-than-expected radioactivity levels are encountered that would be considered nonTENORM; however, Portage is not seeking approval for this facility at this time. Beryllium-contaminated waste from Luckey is not considered RCRA hazardous; however, beryllium does require handling considerations to ensure safety of disposal facility workers. Disposal facilities and waste stream destinations are identified in Table 6-2.

Table 6-2. Disposal facilities and waste types.

Facility Ber

ylliu

m-c

onta

min

ated

soil

with

rad

ioac

tive

CO

C

conc

entr

atio

ns a

t ba

ckgr

ound

Ber

ylliu

m-c

onta

min

ated

soil

with

TE

NO

RM

bel

ow O

hio

exem

ptio

n

Ber

ylliu

m-c

onta

min

ated

soil

with

TE

NO

RM

abo

ve O

hio

exem

ptio

n

Low

-Act

ivity

Rad

ioac

tive

Was

te

Waste Management; Northwood, Ohio (needs USACE acceptance)1 Primary Primary NA NA

US Ecology (formerly Environmental Quality); Wayne, Michigan (pending USACE acceptance)

Backup Backup Primary NA

US Ecology; Grandview, Idaho NA NA Backup Primary 1. Acceptance based upon landfill disposal and exemptions of TENORM-contaminated material

[ORC 3734.02(P)(2), ORC 3748, and OAC 3701].




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6.3.2 In Situ Treatment of Lead-Contaminated FUSRAP Waste

Lead is considered a FUSRAP COC because lead oxide was used as an additive in the beryllium production process. Soil samples from the site were analyzed for total metals; therefore, by applying the 20 times rule to the cleanup goal for lead, the site soil could exceed TCLP. If the soil contaminated with lead demonstrates the TCLP above the regulatory limit of 5 ppm, it is considered RCRA hazardous waste (RCRA code D008) when shipped off-site for disposal. Before bulk excavation in areas where lead is found above the cleanup goal (CG), the location will be stabilized in situ by mixing a treatment additive, EnviroBlend® (or equivalent), using an excavator, as discussed in Section 5.2.1. Verification sampling will be performed twice – once in the amended areas to verify that the soil no longer exceeds the TCLP before excavation, and then after sorting. If necessary, additional treatment will be performed until TCLP levels are met.

6.3.3 Waste Sorting

NonFUSRAP contaminants may result in other waste types requiring treatment and/or additional disposal options; therefore, excavated soil will first be separated into 365-CY feed stockpiles in S1. A composite sample from each feed stockpile will be collected to characterize the soil for chemicals that would require treatment before disposal. If nonFUSRAP chemicals are detected that require treatment, any waste greater than 3.6 pCi/g Ra-226 will be tracked and profiled for shipment. Wastes under the treatment criteria will be managed in the 100-CY stockpiles as discussed below.

ScanSortSM will segregate soil less than and greater than 3.6 pCi/g Ra-226 and convey it into 100-CY stockpiles and waste containers, respectively. The 100-CY stockpiles will then be characterized and segregated as (1) beryllium-contaminated FUSRAP waste (beryllium concentrations above 131 ppm CG), (2) acceptable place-back soil, or (3) nonFUSRAP chemical-contaminated soil. The composite sampling approach for 100-CY stockpiles is described in the SAP. Each waste container will be filled via a ScanSortSM conveyer with approximately 21 tons (11 CY) of material. Waste volume is limited to this weight by the site soil’s bulk density and U.S. Department of Transportation (DOT) road limits. The characterization process and waste disposition path are shown in Figure 6-1. Details on the ScanSort system installation, calibration, and operation are summarized in the SSOP included as Attachment 1.




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6.3.4 Ra-226-Contaminated FUSRAP Waste

Soil with concentrations of Ra-226 over the cleanup goal will be segregated into waste containers by ScanSortSM. The waste containers with soil over the Ohio regulatory TENORM limit of 6.75 pCi/g Ra-226 will be readied for shipment to USEI. For soils found to be less than 5 pCi/g plus the site background of 1.75 pCi/g (Ra-226 <6.75 pCi/g), a detailed ScanSortSM radiological analysis report demonstrating 100 percent characterization will be developed as part of the ODH Bureau of Radiation Protection regulatory concurrence process, demonstrating that the material falls under the TENORM exemption.

6.3.5 NonFUSRAP Chemical-Contaminated Soil

Soils with Ra-226 at less than 3.6 pCi/g will be segregated into 100-CY stockpiles. Portage will transfer nonFUSRAP soil with hazardous constituents above the limits identified in Table 2.2-1 of UFGS, Section 02 61 13 (also included as Appendix B of the BRP), in a similar fashion to the on-site storage area northwest of the processing area. Portage will manage it in accordance with UFGS, Section 02 61 13. Further requirements for handling will be determined in coordination with USACE and OEPA. After soil removal, the 100-CY concrete stockpile bays will be washed down (gross decontaminated) and readied for reuse.

6.3.6 Beryllium-Contaminated FUSRAP Waste

Stockpile soil with beryllium above the CG will be prioritized for removal and packaging. Total lead concentrations above 100 mg/kg will trigger TCLP analysis to confirm the effectiveness of in situ stabilization before disposal. The above-beryllium CG soil that is nonhazardous will be packaged for shipment to Northwood, using a wheel loader equipped with a load cell system for soil weight measurement to manage weights to DOT road standards. Soil below the CG for beryllium, other FUSRAP contaminants, and nonFUSRAP contaminants will be managed as place-back.




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Figure 6-1. Waste characterization process and disposition path.

6.3.7 Acceptable Place-Back Soil

Portage will then analyze stockpile samples below beryllium and lead CG levels for nonFUSRAP constituents listed in Table 2.2-1 of UFGS, Section 02 61 13 (also included as Appendix B of the BRP). Soil testing negative for these constituents will be moved with a wheel loader from the 100-CY stockpile area and transferred to the place-back soil stockpile.




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6.3.8 Debris Processing

Debris segregated based upon hand-held instrument levels will be processed separately if encountered. Other debris will be sized for handling as it is removed before transport to the waste processing and handling area. A stationary grizzly and a quick-change shear/processor will be plumbed for the excavator. As soil that contains debris is encountered, the loader will drop material through the grizzly to ensure that oversized items (>4 in.) are not sent to the soil sorter. Debris requiring size reduction will be placed to the side in a stockpile and size reduced when sufficient quantity is available for a campaign. After size reduction, the debris will be bedded in associated soil waste during waste container loading. Debris waste such as batteries, PCB ballasts, and other Universal Waste that may be encountered during excavation will be stored in the S1 area, managed on a case-by-case basis, and dispositioned at an appropriate disposal facility.

6.4 Waste Packaging and Disposal

6.4.1 Packaging Waste for Off-Site Transport

The waste containers will be lined with waste bags constructed of a polyethylene liner and woven polymeric fabric designed to contain asbestos, which poses an inhalation hazard similar to beryllium. The specifications for procurement of the bags are described in the WMTDP. Each bag will be constructed to fit snugly into a standard 20-ft waste containers. To reduce potential for external waste container contamination, the bag flaps extend over all four edges and down the sides. Waste containers will also have the following features: International Standards Organization (ISO) twist-lock corner fittings, roll-off truck tracks and pulleys, top loading with end dump doors, and tarpaulin or hard top lids.

The waste containers will be prepared for waste receipt in the CRZ (bags installed, absorbent added) and placed on racks in two locations within the S1 EZ. One set of waste containers will be direct-loaded by the radial conveyer and one set by the 3-CY wheel loader. Filled bags (in the waste container) will be zippered shut and enclosed with a lid or tarpaulin. Before release from the EZ, each waste container’s top, bottom, and sides will be visually inspected, surveyed for loose radioactive material and external dose rate (<2 mR at 1 ft), and smeared for radioactivity and beryllium. Each waste container will then be moved from the EZ to the CRZ to the SZ, as discussed below. This process is essential in preventing off-site contamination during waste transportation and disposal.

A reach stacker will operate in the CRZ immediately south of the ScanSortSM system in the waste transportation staging area, as shown in Figure 5-1. From this area the reach stacker arm is capable of picking up and moving waste containers weighing upwards of 40 tons between SZ/CRZ/EZ. The ISO twistlock fittings allow waste containers to be picked-and-placed by the




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reach stacker, reducing contact points to only the corners. Using bag-out processes to cover these areas along with the overlapping flaps of the bag, decontamination of the waste containers once filled will be minimal. Twistlock corners will also fit into inspection stands, making surveys and smears easy to perform.

6.4.2 Radiological and Beryllium Surveys of Waste Containers

Before release from the EZ, the waste containers will be placed on inspection racks and will be visually inspected and surveyed for loose radioactive material and external dose rate, and smeared for radioactivity and beryllium in accordance with CCP. The containers will then be moved into the CRZ where they will be stored until the laboratory smear results are received, approximately 24 hours later. Results below release criteria will allow the release of the waste container for transfer via the reach stacker to the SZ and off-site disposal. If contamination is detected, the reach stacker will be used to move the waste container to the decontamination pad, where contamination will be removed before a new release survey. Procedures for the radiological survey of incoming waste containers and packages destined for off-site transport are presented in the project RPP and for beryllium in the CCP.

6.4.3 Off-Site Waste Transportation and Disposal

USEI, Grandview, Idaho, and Waste Management, Northwood, Ohio (WM Inc.), facilities are expected to receive FUSRAP waste. NonFUSRAP waste transportation and disposal needs are not part of this plan. We evaluated transportation options to these facilities with consideration of such variables as residential area impacts, traffic and accidents, and schedule. Residential areas will be avoided by accessing the Interstate system via Ohio 582 for waste destined for either disposal facility. Routes to each facility are described in detail in the WMTDP. Due to the distance to USEI, access to rail via a trans-load facility is under consideration in nearby Northwood, Ohio, and Walbridge, Ohio. The routes to these facilities represent lower-density residential areas, are less traveled, and therefore have lower accident rates in general than roads north of the site. Use of the same rural route to access the Interstate system for either disposal option reduces impacts to stakeholders, increases our control, and makes full-time tracking of the shipments easier. Scheduling of trucks leaving the site will be planned to avoid high-traffic periods. Inclement weather will be considered for scheduling each load to avoid dangerous road conditions.

WM Inc.’s Evergreen Facility in Northwood, Ohio, is the regional Ohio Subtitle D landfill. This facility is willing to accept exempt TENORM waste and has an approach for handling beryllium hazards. WM Inc. in Northwood accepts and is familiar with handling asbestos – friable/ nonfriable, and construction debris – matrices with similar physical properties to the site waste. Before USACE acceptance of this facility, a beryllium amendment to this program will be initiated. The program will require that waste is shipped in double-contained bags designed to




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withstand tearing during dumping. The waste will be placed in a designated georeferenced disposal area within the facility. Based on 24-hour notice of daily waste volumes, a discrete trench within the disposal cell will be prepared for direct dump of intact bags, followed by immediate placement of cover to further reduce airborne release hazards.

USEI offers proven USACE performance and the best value for the Luckey radiologically contaminated material. USEI can accept soil and debris contaminated with all the Luckey FUSRAP COCs. Waste material will be disposed of at the Grandview, Idaho, disposal facility, which is a RCRA/TSCA Subtitle C, 11e(2), Comprehensive Environmental Response, Compensation, and Liability Act-approved facility. Disposal cells are designed and constructed with three synthetic liners and 8 ft of compacted clay between them, providing both safe and permanent disposal.

6.5 Spill Prevention and Control

Procedures and responsibilities for spill prevention, response activities, and cleanup associated with the remediation and waste transportation at the site are presented in the WMTDP. Spills will be reported in accordance with Engineer Pamphlet 1110-1-33, Spill Reporting Procedures for USACE Hazardous, Toxic and Radioactive Waste Projects (USACE 2008).

6.6 Air Monitoring and Dosimetry

The remediation team will perform two types of air monitoring: ambient air monitoring in active remediation areas of the site, and remediation worker (personal) air monitoring and dosimetry. The breathing zone will be monitored for VOCs using a photoionization detector or flame ionization detector. Dust will be monitored using a miniature real-time aerosol monitor instrument. Beryllium, lead, and radionuclides are the primary contaminants of concern in the dust. Dosimetry will be issued and used by personnel in accordance with the RPP. A third type of monitoring, perimeter air monitoring, will be continuously operated. Detailed descriptions of all air monitoring are included in the APP and CCP.

6.7 Equipment Decontamination

During the course of remediation and at project completion, it will be necessary to demobilize equipment from the site. Equipment that has become contaminated or is potentially contaminated will undergo gross decontamination at the exit point from the trench area. This process uses a high-pressure fire hose from the water truck to remove visible clumps of mud and dirt and reduces the loading on the decontamination pad. The piece of equipment is then moved to the decontamination pad through the EZ. The decontamination pad is equipped with a power washer, vacuum cleaner, and assorted brooms, wipes, and brushes. Some disassembly will likely be necessary to ensure that low-access areas can be adequately evaluated. When the equipment has been decontaminated, it will be surveyed for radiological constituents and smeared for beryllium.




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Upon completion of decontamination and verification that equipment is below radiological release limits, the equipment may be free released. Detailed decontamination and survey procedures are included in the CCP and RPP.

7. FINAL STATUS SURVEY

Incremental, rolling FSSs will be performed as excavation progresses. This will limit concurrent areas of open excavation – an ALARA and best management practice for contamination control – as well as minimizing the volume of groundwater and precipitation requiring treatment. In addition, sequential backfill placement shortens the schedule because excavation and backfill are performed concurrently, adding a safety factor for personnel working on the site by reducing the area of open excavation. Before conducting the FSSs, the excavation operator will cut back any steep slopes to 2:1 so that personnel can enter the excavation safely.

Survey units and unit size will be for Class 1 areas. Gamma radiation surveys using data-loggers and GPS equipment will be used to measure radiation levels over 100 percent of site areas following remediation. This will be done to assure that there are no areas of elevated radiation. Soil samples will be collected at a frequency determined using the formulae in MARSSIM. Systematic samples will be collected using a random start triangular grid. Sufficient volume of sample media will be collected so that they may be split for radiological, beryllium, and lead analysis. This satisfies the SOW requirement to perform a “MARSSIM-like” survey for beryllium and lead and eliminates a separate sampling event for beryllium. Excavated areas will be surveyed from upgradient to downgradient such that areas that might be contaminated by runoff will be surveyed last.

Samples will be analyzed at the on-site laboratory. Ten percent of samples will be sent to an off-site independent third-party laboratory as a quality check on the sample results achieved at the on-site laboratory. Results of all surveys will be documented in an FSS report providing proof that the site remediation objectives were achieved.

The FSS increments will be down-posted from EZ to SZ with a CRZ posted between the EZ and SZ. Following USACE approval, placement and compaction of backfill will begin in each incremental FSS. Details on the approval, placement, and compaction of backfill are provided in the BRP. Placement will begin with clean imported fill, followed by the placement of place-back fill, and topped with topsoil. In accordance with UFGS, Section 02 61 13, the following backfilling sequence will be used:

• Place clean imported fill in the excavation first. The exact quantity of clean imported fill to be placed will be a factor of the water table surface, the depth of the excavation, and the quantity of available place-back fill.




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• Place any place-back soils above the clean imported fill. The maximum quantity of place-back fill that can be placed will be based on the total fill required, minus the required amount of clean imported fill. Portage has determined that it will have place-back fill available to meet these maximum quantity limits. If the potentially available place-back quantity had not been available, additional clean imported fill would have been required.

Portage will obtain clean imported fill and topsoil from off-site sources approved by the KO. Backfill will be classified and tested in accordance with UFGS, Section 02 61 13 (e.g., Table 2.2-2), and will be free from roots and other organic matter, trash, debris, snow, frozen materials, or other undesirable materials as determined by USACE. Portage will not use imported general fill and topsoil for backfill until borrow source test results have been accepted by USACE.

Using a dozer, Portage will construct a ramp into the excavation at each FSS segment, and Portage will continue to pump groundwater as needed to allow compliant placement of backfill. The dozer will push from the ramp into the excavation, creating a peninsula, so the dozer can continue to operate on imported backfill. The relatively short distance the material has to be pushed for each FSS ensures efficient backfill placement. Backfill will be placed in lifts with a maximum loose thickness of 8 in. The fill will be compacted in accordance with the BRP, using a dozer aided by the robotic total station survey equipment to confirm backfill lift heights. The robotic total station will also be used to determine the elevation of the groundwater surface and to establish the top elevation for required clean imported fill.

When the required volume of imported fill has been placed and compacted, cross sections of the backfill area will be surveyed and compared to the surveys performed before backfill placement, using the average end area method, to determine the total quantity of imported fill placed.

Following placement of the clean imported fill, placement of place-back soils taken from on-site stockpiles will begin above the imported backfill. Place-back soils will be placed in lifts and compacted in the same manner as the imported backfill. After all place-back soils have been placed and compacted, cross sections of the backfill area will be surveyed again. The results of this survey will be compared to the surveys performed after the placement of the clean imported fill, using the average end area method, to determine the total quantity of place-back soil placed.

Following placement of the last lift of place-back soil, the area of the FSS will be rough-graded to ensure continuing functionality of erosion control measures. If necessary, these controls will be modified (with USACE KO approval) using the new civil survey data. As described in the approved project site grading plan in the BRP, final site grading will occur after excavation areas have been excavated and backfilled to grade, ensuring necessary grading to restore emergent wetlands where appropriate.




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Once all backfill is in place, a minimum of 4 in of topsoil will be placed above the backfill, in accordance with UFGS, Section 02 61 13. This placement will be performed consistent with the approved BRP to achieve final grade and positive drainage. All topsoil will be imported from off-site sources approved by the USACE KO. Import topsoil will be classified and tested in accordance with UFGS, Section 02 61 13 (e.g., Table 2.2-2). Portage will not use imported topsoil until borrow source test results have been accepted by the USACE.

Cross sections of the area will be surveyed after the required volume of topsoil has been placed and compacted, and survey results will be compared to prior surveys performed after all backfill placement using the average end area method to determine the total quantity of topsoil placed.

Following the placement of topsoil, Portage will seed disturbed soil areas and apply mulch for erosion control to return the site to its natural vegetative state. For application of natural grasses, Portage will apply hydroseeding to the disturbed soil areas after all final surface grades have been completed. The hydroseeding slurry will be transported in a tank, either truck or trailer mounted, and sprayed over the prepared ground. The application of hydroseeding will promote quick growth and assist with erosion control. Mulch will be provided as cover to promote the growth of vegetation and assist with erosion controls where necessary. The seeding mixture will be specified in the BRP and approved by USACE.

8. DEMOBILIZATION

Portage will demobilize from the site at the conclusion of site remediation and restoration activities. Demobilization at the conclusion of remediation will consist of two phases. Personnel and equipment for remediation will be demobilized immediately following completion of excavation, transportation of waste staging and off-site transport, and free release of remediation equipment. All equipment coming into contact with contaminated waste will be decontaminated and radiological and beryllium surveys for unconditional free release of potentially contaminated equipment will be performed before demobilization. Decontamination and free release of equipment are described in the CCP and RPP. Final radiological and beryllium surveys will also be performed for haul roads and temporary decontamination facilities before demobilization from the site. Concrete will be characterized and processed, as necessary, which could include decontamination or scabbling of stained and contaminated areas to minimize waste material. Disposal of concrete will be consistent with disposal of remediation debris and equipment having similar contamination. Soil beneath the concrete will be sampled in accordance with the FSSP.

9. CONSTRUCTION COMPLETION REPORT

Portage will prepare a construction completion report following site restoration and demobilization that provides a summary of remediation activities and results. The report shall include, but not be limited to:




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• The project scope and description. • Remediated areas, including as-built drawings (plan and section) that identify:

o Pre-excavation surfaces and site conditions. o Depths, lateral extent, and volumes of each excavation. o Fill sequences and lines. o Utilities, foundations, or other structures remaining. o Final restored contours.

• Excavation, material handling, and backfilling methods. • Construction/environmental testing results. • Technical data packages that include the results of individual final status surveys/closure

units. • Perimeter air monitoring methods, results, and response actions taken (if appropriate). • Radiation protection and control measures. • Worker safety protection measures implemented and monitoring conducted. • QC activities. • Scope deviations and corrective measures. • Material quantities:

o FUSRAP-contaminated soils (i.e., beryllium only, TENORM, low-activity rad, RCRA waste, and mixed waste).

o NonFUSRAP chemically contaminated soils. o Place-back soils. o Off-site fill.

• Sources of fill. • Waste management, transportation, and disposal methods, including transportation

stations (if used) and disposal facilities. • Completed, signed waste manifests and disposal documentation. • Stormwater and wastewater management activities and monitoring data (if appropriate). • Site restoration drawings, including:

o Backfilling sequence and soil properties. o Final topographic survey. o Topsoil and seeding.

Appendices shall contain all backup documentation generated as part of the work including, but not limited to, the final work plans, log books, permits, inspection records, photographs, laboratory data, meeting minutes, daily reports, and radiological surveys.




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Portage will also prepare draft and final versions of a lessons-learned report for submittal to USACE as well as participate in a USACE lessons-learned conference/meeting, as identified in the SOW. Comments on the draft document will be incorporated into the final version.

10. REFERENCES

49 CFR 173, Subpart I – Class 7 (Radioactive) Materials, Code of Federal Regulations, U.S. Department of Transportation.

Intergovernmental Data Quality Task Force, 2005, Uniform Federal Policy for Quality Assurance Project Plans, March 2005.

USACE, 2016a, Water Management Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project, PLN-5506, U.S. Army Corps of Engineers, Buffalo District, Buffalo, New York.

USACE, 2016b, Contractor Quality Control Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project, PLN-5502, U.S. Army Corps of Engineers, Buffalo District, Buffalo, New York.

USACE, 2016c, Accident Prevention Plan/Site Safety and Health Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project, PLN-5501, U.S. Army Corps of Engineers, Buffalo District, Buffalo, New York.

USACE, 2016d, Chronic Beryllium Disease Prevention Program for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project, PLN-5512, U.S. Army Corps of Engineers, Buffalo District, Buffalo, New York.

USACE, 2016e, Radiation Protection Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project, PLN-5513, U.S. Army Corps of Engineers, Buffalo District, Buffalo, New York.

USACE, 2016f, Contamination Control Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project, PLN-5509, U.S. Army Corps of Engineers, Buffalo District, Buffalo, New York.

USACE, 2016g, Uniform Federal Policy Quality Assurance Project Plan for the Luckey Formerly Utilized Sites Remedial Action Program Site Remediation, Luckey, Ohio, Sampling and Analysis Plan, PLN-5503, U.S. Army Corps of Engineers, Buffalo District, Buffalo, New York.

USACE, 2016h, Backfill and Restoration Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project, PLN-5510, U.S. Army Corps of Engineers, Buffalo District, Buffalo, New York.




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USACE, 2016i, Regulatory Compliance Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project, PLN-5504, U.S. Army Corps of Engineers, Buffalo District, Buffalo, New York.

USACE, 2016j, Waste Management, Transportation, and Disposal Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project, PLN-5507, U.S. Army Corps of Engineers, Buffalo District, Buffalo, New York.

USACE, 2016k, Final Status Survey Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project, PLN-5508, U.S. Army Corps of Engineers, Buffalo District, Buffalo, New York.

USACE, 2014a, Final Scope of Work, Remediation of Soils Operable Unit, Luckey Site, U.S. Army Corps of Engineers, Luckey, Ohio, May 2014.

USACE, 2014b, Safety and Health Requirements, Engineer Manual 385-1-1, U.S. Army Corps of Engineers, November 30, 2014.

USACE, 2008, Spill Reporting Procedures for USACE Hazardous, Toxic and Radioactive Waste Projects, Engineer Pamphlet EP 1110-1-33, U.S. Army Corps of Engineers, November 2008.

USACE, 2007, Safety and Occupational Health Requirements for Hazardous, Toxic and Radioactive Waste Activities, Engineer Manual 385-1-92, U.S. Army Corps of Engineers, May 2007.

USACE, 2006, Luckey Site, Luckey, Ohio, Record of Decision for Soils Operable Unit, Final, prepared for U.S. Army Corps of Engineers, Buffalo District, prepared by Science Applications International Corporation, Twinsburg, Ohio, June 2006.

USACE, 2001, Requirements for the Preparation of Sampling and Analysis Plans, Engineer Manual 200-1-3, U.S. Army Corps of Engineers, February 2001.

USACE, 2000, Luckey Site, Luckey, Ohio, Final Remedial Investigation Report, Luckey Site, prepared for U.S. Army Corps of Engineers, Buffalo District, prepared by Science Applications International Corporation, Dublin, Ohio, September 2000.

USEPA SW-846, Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, U.S. Environmental Protection Agency.

USEPA, NRC, DoD, and DOE, 2000, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM), EPA 402-R-97-016, Rev. 1, U.S. Environmental Protection Agency, U.S. Nuclear Regulatory Commission, U.S. Department of Defense, and U.S. Department of Energy, August 2000.

USEPA 833-R-060-04, Developing Your Stormwater Pollution Prevention Plan, A Guide for Construction Sites, U.S. Environmental Protection Agency, May 2007.




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APPENDIX A Project Schedule




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APPENDIX B Résumés of Key Project Personnel




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APPENDIX C Drawings




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Index of Appendix C Drawings • Phase 1 Fencing and Grubbing Plan • Phase 2 Fencing, Clearing and Grubbing Plan • Phase 2 Parking and Transport Road • Phase 2 Water and Utilities Plan • Phase 4 Clearing, Grubbing & Hot Spot Removal • Phase 4 Fencing Plan • Phase 4 Geomembrane Plan • Phase 4 Liner Profile • Phase 4 Concrete Pads • Phase 4 Butler Building Details • Phase 4 Concrete Pad Slab Details • Phase 4 Electrical Utilities




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ATTACHMENT 1 Soil Sorting Operations Plan

PLN-5505 Rev. 2

Soil Sorting Operations Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project

U.S. Army Corps of Engineers Buffalo District, Buffalo, New York

Contract No. W912P4-15-D-0006, Delivery Order 0001 Prepared by: Amec Foster Wheeler E&I under contract to Portage, Inc. 1075 S. Utah Ave., Suite 200 Idaho Falls, ID 83402

Applicability: Luckey FUSRAP Remediation

Effective Date: 08/01/17 Owner: Project Manager

Signature:

SOIL SORTING OPERATIONS PLAN FOR THE LUCKEY FORMERLY UTILIZED SITES REMEDIAL

ACTION PROGRAM REMEDIATION PROJECT


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This Soil Sorting Operations Plan (SSOP) has been created by Amec Foster Wheeler in cooperation with Portage, Inc. (Portage). This SSOP contains information relating to intellectual property of a confidential and proprietary nature that Amec Foster Wheeler considers to be a Trade Secret belonging to Amec Foster Wheeler. Its unauthorized use, disclosure, modification, or distribution to the public is prohibited. Users expressly authorized by Amec Foster Wheeler in writing are permitted to obtain this document for the specified purpose only. Amec Foster Wheeler has been contracted by Portage to perform soil sorting services in support of its contract with the U.S. Army Corps of Engineers for the remediation of the Luckey FUSRAP Site located in Luckey, Ohio. Amec Foster Wheeler hereby authorizes only the official use of this information in connection with its application to the Luckey FUSRAP Site Remediation Project. For information regarding approved use of this document, contact: Amec Foster Wheeler Corporation 2275 Logos Court, Suite A Grand Junction, CO 81505 970-243-2861

Site Operations Plan for the Luckey Formerly Utilized ......Project organization chart. ..... 26...

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Transcript of Site Operations Plan for the Luckey Formerly Utilized ......Project organization chart. ..... 26...