Building Deconstruction Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project U.S. Army Corps of Engineers ...
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PLN-60066-001
Rev. 0
Building Deconstruction Plan for the Luckey Formerly
Utilized Sites Remedial Action Program Remediation
Project
U.S. Army Corps of Engineers (USACE)
Buffalo District, Buffalo, New York
Applicability: Luckey FUSRAP Effective Date: 12/16/2020
Building Deconstruction
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Completion of Independent Technical Review
This document has been produced within the framework of the North Wind Site Services quality
management system. As such, an independent technical review (ITR), appropriate to the level of
risk and complexity inherent in the project, has been conducted. This included review of
assumptions (methods, procedures, and material used in analyses), alternatives evaluated; the
appropriateness of data used and level of data obtained; and reasonableness of the results,
including whether the product meets the project objectives. Comments and concerns resulting
from review of the document have been addressed and corrected as necessary.
Document: Building Deconstruction Plan for the Luckey Formerly Utilized Sites Remedial
Action Program Remediation Project
Developed by: North Wind Site Services, LLC
ITR performed by:
Title: Alternate Project Manager
Company: North Wind Site Services, LLC
Signature: Date: 12/16/2020
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History of Revisions
Revision Issue Date Action Description
0 12/16/2020 New document. Initial issue.
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Table of Contents
1. INTRODUCTION ................................................................................................................10
1.1 Purpose .....................................................................................................................10
1.2 Scope of Work and Approach ..................................................................................10
1.3 Deconstruction Plan Organization ...........................................................................12
2. SITE DESCRIPTION ..........................................................................................................13
2.1 Site Location ............................................................................................................13
2.2 Site History ...............................................................................................................13
2.3 Buildings ..................................................................................................................17
2.4 Underground Utilities ...............................................................................................17
2.5 Drainage Ditches ......................................................................................................18
2.6 Organic Contaminants ..............................................................................................18
2.7 Existing Conditions ..................................................................................................18
2.8 Regulatory Compliance ............................................................................................19
2.8.1 Regulatory Requirements ........................................................................19
2.8.2 Permitting ................................................................................................19
2.8.3 Administrative Record.............................................................................20
3. ORGANIZATION AND RESPONSIBILITIES ..................................................................20
3.1 USACE Responsibilities ..........................................................................................20
3.2 North Wind Site Services Responsibilities ..............................................................20
3.3 Subcontractor Responsibilities .................................................................................21
4. PROJECT SCHEDULE .......................................................................................................22
4.1 Schedule Summary ...................................................................................................22
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4.2 Work Hours ..............................................................................................................26
5. TECHNICAL APPROACH .................................................................................................31
5.1 Mobilization and Preparatory Work (331XX01) .....................................................31
5.1.1 Submittals/Implementation Plans (331XX0103) ....................................33
5.2 Monitoring, Sampling, Testing, and Analysis (331XX02) ......................................34
5.2.1 Air Monitoring, Sampling, Testing, and Analysis ..................................35
5.2.2 Wastewater Monitoring, Sampling, Testing, and Analysis .....................36
5.2.3 Waste and Debris Monitoring, Sampling, Testing, and Analysis ...........36
5.3 Site Work (331XX03) ..............................................................................................36
5.3.1 Pre-remediation Land Survey, Inspection, and Photographic
Documentation ........................................................................................36
5.3.2 Haul Routes, Parking Areas, and Support Areas .....................................37
5.3.3 Debris Staging Area ................................................................................37
5.3.4 Security ....................................................................................................37
5.4 Surface Water Collection and Control (331XX05) ..................................................39
5.5 Liquids/Sediments/Sludges Collection and Containment (331XX09).....................40
5.6 Drums/Tanks/Structures/Miscellaneous Deconstruction and Removal (331XX10)
..................................................................................................................................40
5.6.1 General Deconstruction Approach ..........................................................40
5.6.2 Excavation and Backfill ..........................................................................42
5.6.3 Building Deconstruction Implementation ...............................................43
5.7 Disposal (Commercial) (331XX19) .........................................................................45
5.8 Site Restoration (331XX20) .....................................................................................46
5.9 Demobilization (331XX21)......................................................................................46
5.10 General Requirements (331XX22)...........................................................................47
5.10.1 Supervision and Management (331XX2201) ..........................................47
5.10.2 Asbestos Hazard Evaluation Specialist ...................................................50
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5.10.3 Engineering, Surveying, and Quality Control (331XX2204) ..................50
5.10.4 First Aid, Fire Protection, Traffic Control, and Security (331XX2206) .50
5.10.5 Health and Safety (331XX2207) .............................................................51
5.10.6 Radiation Protection ................................................................................54
5.10.7 Radiation Safety Officer ..........................................................................54
5.10.8 Temporary Construction Facilities ‒ Ownership (331XX2208) .............55
5.10.9 Temporary Construction Facilities – Operation (331XX2209)...............55
5.10.10 Project Utilities (331XX2210) ................................................................56
6. DOCUMENTATION ...........................................................................................................57
7. REFERENCES .....................................................................................................................58
APPENDIX A Critical Path Method Schedule
ATTACHMENT 1 Professional Engineer Certification
ATTACHMENT 2 Pre-Deconstruction Engineering Survey Form
Figures
Figure 2-1. Site Location Map ...................................................................................................... 14
Figure 3-1. Project Organizational Chart. ..................................................................................... 21
Figure 4-1. Preliminary Site Work and Site Preparation .............................................................. 27
Figure 4-2. Maintenance Office Building Deconstruction ........................................................... 28
Figure 4-3. Production and Main Office Building Deconstruction .............................................. 29
Figure 4-4. Complete Building Deconstruction ............................................................................ 30
Tables
Table 4-1. Activity, Personnel, Equipment, and Subcontractors for the Work ............................ 22
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ACRONYMS AND ABBREVIATIONS
ACM asbestos-containing material
AEC Atomic Energy Commission
AED automated external defibrillator
AHA activity hazard analysis
AHES asbestos hazard evaluation specialist
ALARA as low as reasonably achievable
APP Accident Prevention Plan
ASSP American Society of Safety Professionals
BBC Brush Beryllium Company
Be beryllium
BeLPT beryllium lymphocyte proliferation testing
BMP best management practice
CBDPP Chronic Beryllium Disease Prevention Program
CCP Contamination Control Plan
CCTV closed-circuit television
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
CIH certified industrial hygienist
COC constituent of concern
CPR cardiopulmonary resuscitation
CQCP Contractor Quality Control Plan
CQCSM construction quality control system manager
CRZ contamination reduction zone
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EM engineer manual
EZ exclusion zone
ft foot (feet)
FTP File Transfer Protocol
FUSRAP Formerly Utilized Sites Remedial Action Program
GPR ground-penetrating radar
IH industrial hygiene
IP-1 Industrial Package 1
IPR Industrial Properties Recovery, LLC
KO Contracting Officer
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NWP North Wind Portage
ODH Ohio Department of Health
ODOT Ohio Department of Transportation
OSH occupational safety and health
OSHA Occupational Safety and Health Administration
OU operable unit
PBZ personal breathing zone
PCB polychlorinated biphenyl
PM project manager
PPE personal protective equipment
QA quality assurance
QC quality control
RFP request for proposal
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1. INTRODUCTION
The United States Army Corps of Engineers (USACE), Buffalo District, has contracted North
Wind Site Services, LLC, (North Wind Site Services) under Contract Number W912P420C0013
to perform deconstruction and removal of the production, maintenance office, and main office
buildings at the Luckey site. The site is being remediated under the USACE’s Formerly Utilized
Sites Remedial Action Program (FUSRAP).
The site was used for beryllium processing in support of the national defense program. Atomic
Energy Commission (AEC)-related production activities and operations occurred at the site from
1949 to 1961. Beryl ore (beryllium aluminum silicate), scrap metal, and radioactive
contaminated scrap metal were brought to the site during this period. The site has been identified
as having materials contaminated with FUSRAP-related constituents of concern (COCs), which
include beryllium (Be), lead, radium-226, thorium-230, uranium-234, and uranium-238. The
buildings to be deconstructed and removed under Contract Number W912P420C0013 likely
have asbestos-containing materials and lead-based paint.
1.1 Purpose
The purpose of this Building Deconstruction Plan is to present the approach for the safe
deconstruction and removal of the production, maintenance office, and main office buildings’
components and debris. It presents the approach, means, methods, requirements, safety
precautions, and documentation required.
Site buildings are being deconstructed for the following reasons:
• The USACE modeled extent of FUSRAP soil contamination extends beneath the
production building.
• Deteriorated conditions of the production building, maintenance office building, and
main office building present safety hazards to site workers when conducting
investigations to determine the presence of FUSRAP contamination underneath the
buildings.
1.2 Scope of Work and Approach
The scope of work as presented in the Performance Work Statement, Luckey Building
Deconstruction, Luckey FUSRAP Site, Luckey, Ohio (USACE 2020a), and further defined in
North Wind Site Services’ Revised Technical Proposal dated August 24, 2020 (North Wind
2020), is summarized as follows:
• Provide for worker safety, including a beryllium monitoring program.BUILDING DECONSTRUCTION PLAN FOR THE Identifier: PLN-60066-001
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• Provide radiation protection and health physics support during the performance of the
work.
• Installation, operation, and maintenance of permanent and mobile air monitoring stations.
• Environmental sample collection, handling, analysis, and reporting.
• Water treatment system maintenance as needed (the system will not be utilized as part of
the deconstruction effort).
• Wastewater storage and disposal off-site.
• Operation and maintenance of the Potable Water System.
• Database programming and maintenance.
• Waste classification, manifesting, shipping, and disposal.
• Building deconstruction and debris disposal.
• Site restoration.
• Preparation of project plans, reports, and documentation.
The deconstruction approach involves plan preparation and approval, deconstruction of the
buildings, sizing of the debris, loading of debris into containers, transportation of the loaded
containers to the licensed disposal facility, monitoring, site restoration, and closeout. The effort
begins with mobilization and the preparation and approval of this Deconstruction Plan and
associated work plans (adapted from the existing Luckey Site Soils Operable Unit [OU] work
plans prepared under Contract Number W912P4-15-D-0006) addressing the work activities
associated with the deconstruction. Following approval of the planning documents, field
activities will be performed in three phases.
Preliminary site work includes stand-up of field operations and safety training of personnel;
identification of underground utility locations; identification of the support, contamination, and
exclusion zones; construction of haul routes around the perimeter of the buildings to be
deconstructed; cutting and capping of utilities; preparation of existing staging/laydown areas;
installation of storm water erosion prevention materials; and installation of perimeter air
monitoring stations.
Site preparation includes full mobilization of the project team, additional safety training,
termination of utilities, establishing support areas, controls, and monitoring. Building
deconstruction includes conducting an internal readiness review, installation of dust controls and
means to capture any runoff, deconstruction of the buildings, sizing of the debris and loading
into containers for transportation to the licensed disposal facility, site restoration, and closeout.BUILDING DECONSTRUCTION PLAN FOR THE Identifier: PLN-60066-001
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It is important to recognize that, due to their current condition, the buildings have been deemed
unsafe for entry and will be deconstructed without conducting a hazardous material survey or
any abatement of hazardous materials. Accordingly, it is assumed that all of the debris generated
will be regulated asbestos containing material per the state of Ohio Environmental Protection
Agency regulations. Therefore, the deconstruction activities will proceed utilizing the
appropriate health, safety, environmental, and contamination controls. North Wind Site Services
will deconstruct the buildings so as to provide a level of protection to the public and remediation
workers consistent with applicable exposure limits and with the objective of maintaining
chemical and radiological exposure levels as low as reasonably achievable (ALARA).
1.3 Deconstruction Plan Organization
This Building Deconstruction Plan presents methods, procedures, and facilities that will be used
to complete the building deconstruction in accordance with USACE guidelines, maintaining a
safe and productive work environment. It describes the overall plan for completing the
mobilization, deconstruction, and restoration of the site and provides information as required by
the Performance Work Statement (USACE 2020a). The remainder of this Plan is broken up into
the following sections:
• Site Description – includes the site location, a brief site history, existing conditions, and
regulatory compliance.
• Organization and Responsibilities – presents the project team organization and
responsibilities, including USACE, North Wind Site Services, and subcontractors.
• Project Schedule – presents the project schedule.
• Technical Approach – covers the project plans, site layout and preparation, monitoring,
the deconstruction of the buildings, material processing, packaging and staging of the
debris, transportation, disposal, and site restoration.
• Documentation – includes the record keeping and reporting performed to properly
document the deconstruction of the buildings.
• References – includes a listing of the applicable reports and documents associated with
this plan and the completion of the deconstruction work.
• Appendix – includes the project critical path schedule.
• Attachments ‒ include the professional engineer certification of the structural safety of
the deconstruction process, and the pre-deconstruction engineering survey form.
This Plan is based on information available at the time of its preparation. Future modifications,
conditions encountered, and findings as deconstruction progresses may necessitate revision to
this Plan. If modifications become necessary, they will be justified, documented, and approved
by the USACE before implementation. This Plan focuses on the technical approach forBUILDING DECONSTRUCTION PLAN FOR THE Identifier: PLN-60066-001 LUCKEY FORMERLY UTILIZED SITES REMEDIAL Revision: 0 ACTION PROGRAM REMEDIATION PROJECT Page: 13 of 67 deconstruction. It is supported by ancillary project-specific plans and includes a summary of the applicable requirements to provide a more complete understanding of the deconstruction approach. 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 the 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 farmland with several residential properties and a former quarry to the south. From 1949 to the early 1960s, the Brush Beryllium Company (BBC), 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. 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 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.
BUILDING DECONSTRUCTION PLAN FOR THE Identifier: PLN-60066-001 LUCKEY FORMERLY UTILIZED SITES REMEDIAL Revision: 0 ACTION PROGRAM REMEDIATION PROJECT Page: 14 of 67 Figure 2-1. Site Location Map
BUILDING DECONSTRUCTION PLAN FOR THE Identifier: PLN-60066-001 LUCKEY FORMERLY UTILIZED SITES REMEDIAL Revision: 0 ACTION PROGRAM REMEDIATION PROJECT Page: 15 of 67 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. In 1967, 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. 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. The following is a listing of all of the buildings, (some have since been removes and are noted as such). Large buildings at the site: • Production building. • Production annex (removed). • Melting, alloying, and shipping building.
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• Laboratory building.
• Maintenance office building.
• Main office.
• Employee activity building.
Small structures at the site:
• Pump house (for fire protection water – removed).
• East and west well houses (removed).
• Guard house.
• Shack (removed).
• 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.
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 established cleanup values in the Luckey Site
Record of Decision for Soils Operable Unit, Final (USACE 2006). Documented material
handling and disposal areas at the site 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.BUILDING DECONSTRUCTION PLAN FOR THE Identifier: PLN-60066-001
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2.3 Buildings
Previous surveys and analyses conducted as part of the 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.
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 surface contamination guidelines. Most 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 office
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.
2.4 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) south of the sewage treatment plant
contained beryllium above the site cleanup goal.BUILDING DECONSTRUCTION PLAN FOR THE Identifier: PLN-60066-001
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• Soil surrounding an underground utility line in the vicinity of Lagoons B and C contained
beryllium and radionuclides above the site cleanup goals.
2.5 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
soil/sediment east of the ditch may represent materials that were previously excavated from
the ditch.
2.6 Organic Contaminants
Organic contaminants were detected in site soils during the remedial investigation (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 the soil remedial
action is not determined by these contaminants or by other contaminants that may be present at
the site.
2.7 Existing Conditions
Currently the site is set up to support the Soils Remediation effort being performed by North
Wind Portage (NWP). Considerable soils removal and restoration work will have been
completed prior to the start of building deconstruction. This includes the restoration of the
lagoon area south of the production building. However, the soils work will be suspended during
the deconstruction effort, and respective infrastructure will be transitioned over to North Wind
Site Services during mobilization for deconstruction. This includes the following:BUILDING DECONSTRUCTION PLAN FOR THE Identifier: PLN-60066-001
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• Exclusion, Contamination Reduction, and Support Zones for the excavation, loading, and
staging of contaminated soil.
• Administration Operations Area.
• Wastewater Treatment Plant (except for the reverse-osmosis treatment unit).
• Potable Water Treatment Plant.
• Staging areas.
• Decontamination and access control facilities.
• Haul roads.
• Electrical utilities.
• Fencing.
All but the Wastewater Treatment Plant will be used.
2.8 Regulatory Compliance
2.8.1 Regulatory Requirements
USACE is the lead federal agency for this remedial action and has overall responsibility for
execution of the project in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) and its implementing regulations found in the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP), Title 40 of the Code
of Federal Regulations (CFR) Part 300.
North Wind Site Services will comply with all federal, state, and local regulations while
performing work under this contract. The project regulatory compliance requirements are
provided in detail in PLN-60066-006, Regulatory Compliance Plan.
2.8.2 Permitting
Pursuant to Section 121(e) of CERCLA (42 USC 9621[e]), permits typically required under
federal and state laws or statutes (such as the Federal Clean Water Act [33 USC § 1251 et seq.]
or Clean Air Act [42 USC § 7401 et seq.]) are not required for the portion of remedial actions
conducted on-site. However, on-site operations completed by USACE and its contractors must
comply with all substantive requirements of federal, state, and local laws and regulations.
Permits required for off-site operations (e.g., solid waste transport) will be obtained through the
appropriate regulating entity and the U.S. Department of Transportation. Additional details on
the permits associated with off-site waste management and handling are discussed inBUILDING DECONSTRUCTION PLAN FOR THE Identifier: PLN-60066-001
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PLN-60066-008, Waste Management, Transportation, and Disposal Plan (WMTDP). Ohio
Department of Transportation Special Hauling Permits may be necessary in the delivery and
demobilization of facilities and equipment to/from the site, and vendors will identify them during
the procurement process.
2.8.3 Administrative Record
The administrative record file for the Luckey site is at the following locations:
U.S. Army Corps of Engineers
1776 Niagara Street
Buffalo, New York 14207
Luckey Public Library
228 Main Street
Luckey, Ohio 43443
3. ORGANIZATION AND RESPONSIBILITIES
This section presents the organizational chart for the project and summarizes responsibilities by
organization. Supervision and management responsibilities are described in Section 5.10.1. A
project organization chart is provided as Figure 3-1.
3.1 USACE Responsibilities
USACE, Buffalo District, is the lead federal agency for this remedial action and has overall
responsibility for execution of the project in accordance with CERCLA and its implementing
regulations found in the NCP, Title 40 CFR Part 300.
3.2 North Wind Site Services Responsibilities
North Wind Site Services will provide personnel to support all activities, including on-site
resources and corporate reach-back support as necessary. Designated key personnel will be on-
site during field activities as required. Direct oversight and management of work will be led by
the project manager and matrixed through the site superintendent, site safety and health officer
(SSHO), and construction quality control system manager (CQCSM).
The North Wind Site Services Project Management team will manage the day-to-day field
activities during the building deconstruction. Key project personnel and their responsibilities are
identified in Section 5.10.1.BUILDING DECONSTRUCTION PLAN FOR THE Identifier: PLN-60066-001 LUCKEY FORMERLY UTILIZED SITES REMEDIAL Revision: 0 ACTION PROGRAM REMEDIATION PROJECT Page: 21 of 67 3.3 Subcontractor Responsibilities North Wind Site Services will build upon the existing Soil Remediation infrastructure in place and will utilize subcontractors familiar with the project requirements and working at the site. This includes Civil and Environmental Consultants, Inc., for quality assurance (QA) inspection and air monitoring, NCES for asbestos oversight, I.C.E. Service Group for waste transportation, US Ecology for waste disposal, and BCA Express for yard trucking services. Figure 3-1. Project Organizational Chart. North Wind Site Services employees are represented in blue.
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4. PROJECT SCHEDULE
4.1 Schedule Summary
A Critical Path Method schedule for the project is presented in Appendix A of this plan. This
schedule will be tracked and updated as required. This plan includes the baseline schedule
current at the time of plan approval. Modifications to the schedule will be provided and
documented independent of the deconstruction plan (e.g., there is no need to reissue this plan if
the scheduled is modified).
The schedule starts with the preparation and approval of the work plans followed by site
preparation and then building deconstruction.
The work identified and resources anticipated are presented in Table 4-1, and a more detailed
description is provided in Section 5. Figures 4-1 to 4-4 illustrate the planned progression of the
work.
Table 4-1. Activity, Personnel, Equipment, and Subcontractors for the Work
Activity Personnel Equipment Subcontractors
Work Plans
This will include preparation of a draft, The plans will be Not Applicable Not Applicable
USACE review and comment, addressing coordinated by the
USACE comments and revision to the draft, Project Manager with
USACE review and acceptance of the revised support from the
plan, and preparation and issuance of the final project team in
plan. Most of the plans are adapted from various remote
current plans developed for the Soil OU; also, locations.
several new plans will be developed
specifically for the deconstruction project.
Activity hazard analyses (AHAs) will be
developed for each task and included in the
Accident Prevention Plan (APP)/Site Safety
and Health Plan (SSHP). Job steps, hazards,
and controls are listed within the AHA for
each task.
North Wind Site Services will participate in
site meetings with NWP (the Soil OU
contractor) and the USACE to get a complete
understanding of the site conditions, available
facilities, current work practices and plans,
and to prepare for the site transition.BUILDING DECONSTRUCTION PLAN FOR THE Identifier: PLN-60066-001
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Table 4-1. (continued)
Activity Personnel Equipment Subcontractors
Preliminary Site Work
• Establishment of on-site management and • Project Manager • Gators • Structural
controls Engineers
• Site Safety and • Pickup (Matrix)
• Personnel training and safety reviews Health Officer Trucks
• Utility
• Run on-site potable water treatment • Site • Excavator Locators
system Superintendent (Matrix)
• Haul Truck
• Establish wastewater storage and • Radiological
management Superintendent • Skidsteer
• Complete review of available information • Radiological
and the status of the building utilities Technician
• Confirm status of utilities for each • Foreman
building and identify unknowns
• Mechanic
• Perform limited clearing and grubbing to
allow inspection of building utilities • Operator
• Use ground-penetrating radar (GPR) to • Truck Driver
locate underground utilities as needed • Laborers (2)
• Cut/cap/plug utilities • BeFinder Tech
• Confirm protection plan for the north wall • Project Engineer
of the maintenance office (to protect the
ModuTank during deconstruction) • Quality Control
Manager
• Install storm water pollution prevention
controls in accordance with PLN-60066- • Industrial
012 as needed Hygiene (IH)
Technician
• Install perimeter asbestos-containing
material (ACM) air monitoring stations
and maintain/monitor meteorological
stationBUILDING DECONSTRUCTION PLAN FOR THE Identifier: PLN-60066-001
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Table 4-1. (continued)
Activity Personnel Equipment Subcontractors
Site Preparation
• Personnel training/safety reviews • Project Manager • Gators • Structural
• Site Safety and Engineers
• Airgap and confirm building as cold and • Pickup (Matrix)
dark Health Officer Trucks
• Industrial • 3rd-Party
• Construct laydown staging areas specific • Excavator Asbestos
Hygiene
for building deconstruction Subcontractor
Technician • Haul Truck
• Install additional best management (NCES)
• Safety • Skidsteer
practices (BMPs) and dust controls as Technician • QA & Air
needed Monitoring
• Construction (Civil and
• Collect samples from groundwater Quality Manager Environmental
monitoring wells, production wells, and • Quality Control Consultants,
water supply for analysis at off-site Technician Inc.)
laboratory
• Site • Storm Water
• Relocate site truck scale Superintendent Pollution
• Radiological Prevention
Superintendent Plan (SWPPP)
Management
• Radiological
Technicians (2)
(Civil and
Environmental
• Chemist Consultants,
• Laboratory Inc.)
Technician
• Waste Manager
• Waste
Technician
• Project Engineer
• Project
Coordinator
• Data Manager
• Project Controls
• Foreman
• Welder/Mechanic
• Operator (4)
• Truck Driver
• Laborers (4)
• BeFinder TechBUILDING DECONSTRUCTION PLAN FOR THE Identifier: PLN-60066-001
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Table 4-1. (continued)
Activity Personnel Equipment Subcontractors
Building Deconstruction
• Personnel Training/Safety Reviews • Project Manager • Gators • Structural
• Site Safety and Engineers
• Perform Final Readiness Review • Pickup (Matrix)
Health Officer Trucks
• Set up deconstruction work area • Industrial • 3rd-Party
perimeter air monitoring, and personnel Hygiene • Excavators Abatement
air monitoring for Be, asbestos, Technician (2) (4) Subcontractor
radiological, and dust prior to the start of (NCES)
• Safety • Haul Truck
any building deconstruction work.
Technician (# will • QA & Air
• Run on-site potable water treatment • Construction vary) Monitoring
system Quality Manager (Civil and
• Yard Trucks
• Perform deconstruction, waste mixing, • Quality Control (1 to 2) Environmental
and packaging Technician Consultants,
• Site Superintendent
• Water Truck Inc.)
• Perform dust control
• Radiological • Dust
• SWPPP
• Collect impacted water, sample, and Superintendent Control
Management
dispose of off-site • Radiological Misters (4)
(Civil and
• Load and assay Industrial Package 1 (IP- Technicians (4) • Lifts for Environmental
1) containers • Chemist Misters (1) Consultants,
• Laboratory Inc.)
• Transport released containers to US • Fork Lifts
Ecology for disposal Technician (1) • Waste
• Waste Manager Transportation
• Clean and stabilize building foundations • Waste Technician
• Added Frac (I.C.E Service
Tanks (3) Group)
• Evaluate samples using BeFinder and on- • Project Engineer
site radiological instrumentation • Field Engineer • Pumps, • Waste
generators, Disposal (US
• Collect groundwater samples for off-site • Project
and piping Ecology)
analysis Coordinator
• Data Manager
• Decontaminate and assay trucks and
equipment prior to demobilization • Project Controls
• Project
• Demobilization
Accountant
• Foreman
• Welder/Mechanic
• Operator (5)
• Truck Driver
• Laborers (8)
• BeFinder TechBUILDING DECONSTRUCTION PLAN FOR THE Identifier: PLN-60066-001 LUCKEY FORMERLY UTILIZED SITES REMEDIAL Revision: 0 ACTION PROGRAM REMEDIATION PROJECT Page: 26 of 67 4.2 Work Hours Standard work hours for the site will be 6:00 a.m. to 5:30 p.m., Monday through Thursday, and based on daylight conditions. Any changes to workday start times will be coordinated with the USACE and project personnel. 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.
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Figure 4-1. Preliminary Site Work and Site PreparationBUILDING DECONSTRUCTION PLAN FOR THE Identifier: PLN-60066-001
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Figure 4-2. Maintenance Office Building DeconstructionBUILDING DECONSTRUCTION PLAN FOR THE Identifier: PLN-60066-001
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Figure 4-3. Production and Main Office Building DeconstructionBUILDING DECONSTRUCTION PLAN FOR THE Identifier: PLN-60066-001
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Figure 4-4. Complete Building DeconstructionBUILDING DECONSTRUCTION PLAN FOR THE Identifier: PLN-60066-001
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5. TECHNICAL APPROACH
The overall approach to the deconstruction begins with the preparation and approval of the
required plans. Following approval of planning documents, field activities will be performed.
This section presents the technical approach in the HTRW Remedial Action work breakdown
structure, which is consistent with the layout of the project schedule.
• Mobilization and Preparatory Work (331XX01)
o Submittals/Implementation Plans (331XX0103)
• Monitoring, Sampling, Testing, and Analysis (331XX02)
• Site Work (331XX03)
• Surface Water Collection and Control (331XX05)
• Liquids/Sediments/Sludges Collection and Containment (331XX09)
• Drums/Tanks/Structures/Miscellaneous Deconstruction and Removal (331XX10)
o Deconstruction Work Plan Implementation
• Disposal (Commercial) (331XX19)
• Site Restoration (331XX20)
• Demobilization (331XX21)
• General Requirements (331XX22)
o Supervision and Management (331XX2201)
o Engineering, Surveying, and Quality Control (331XX2204)
o First Aid, Fire Protection, Traffic Control, and Security (331XX2206)
o Health and Safety (331XX2207)
o Temporary Construction Facilities – Ownership (331XX2208)
o Temporary Construction Facilities – Operation (331XX2209)
o Project Utilities (331XX2210)
5.1 Mobilization and Preparatory Work (331XX01)
North Wind Site Services will work closely with the USACE and NWP (contractor with facilities
on-site) to identify efficiencies in the sharing of infrastructure needs at the site. Due to space
constraints and limited utility infrastructure, North Wind Site Services will share infrastructureBUILDING DECONSTRUCTION PLAN FOR THE Identifier: PLN-60066-001 LUCKEY FORMERLY UTILIZED SITES REMEDIAL Revision: 0 ACTION PROGRAM REMEDIATION PROJECT Page: 32 of 67 where appropriate. Primary facilities expected to be utilized are shown on Figure 4-1 and include, but are not limited to: • Personnel shower facilities. • Access control trailer. • Decontamination pad and Rubb® structure. • Potable water treatment system. • On-site laboratory (only the BeFinder® instrumentation and Protean smear counters). • On-site truck scale. • Office and break facilities. Mobilization will commence following USACE approval of the appropriate planning documents. A description of the planning document activity is provided in Section 5.1.1. Initial mobilizations will include required equipment, materials, and subcontractors needed to support pre- deconstruction activities. Equipment mobilization will be sequenced to ensure that equipment is delivered and ready for use to minimize any delays or costs associated with under-utilization. All equipment arriving on- site will be inspected and surveyed to ensure that all safety components are in place (cages, fire extinguishers, etc.), and that the equipment is operationally sound (e.g., no leaks). An incoming radiological survey will be conducted on all arriving equipment. Rubber tire backhoes, skidsteer loaders, bulldozer, aerial lifts, and other supporting equipment will be mobilized during the initial mobilization. Site setup and deconstruction will require additional equipment, materials, and subcontractors to support the deconstruction, processing, loading, transportation, and disposal of the production building and annex building debris. It is anticipated that this will include two 110,000-pound class excavators (or similar) with deconstruction cage, which will be used for the deconstruction of the production building superstructure. Smaller, 80,000-pound class excavators with various attachments, such as bucket and thumb, grapple, metal shear, concrete pulverizers, and hammers, will be used for the size reduction and loading of the waste into containers for disposal. Additional support equipment including, but not limited to, a yard container truck, skidsteer with attachments, water trucks, manlifts, and misters, will also be utilized. Equipment and logistics associated with packaging and transportation of the waste will be provided by the existing subcontractors US Ecology and I.C.E. Service Group and utilize the same approach used by the current NWP team for packaging, transportation, and disposal of contaminated soil.
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5.1.1 Submittals/Implementation Plans (331XX0103)
All submittals will go through an internal review by a multifunctional review team, have an
Independent Technical Review performed, and a final technical edit (formatting) performed prior
to submission to USACE. All submittals will be uploaded to and tracked via the USACE
Resident Management System (RMS). For files of significant size, North Wind Site Services will
utilize a separate File Transfer Protocol (FTP) site to allow ease of uploading and downloading
for the project team. Access to the FTP site is 24/7 and has effectively been used on the NWP
project for sharing of large files. The electronic sharing of documents is also a green and
sustainable practice that minimizes printing, shipping energy, and resource consumption during
plan development.
North Wind Site Services does not expect to perform soil remediation in completing the
deconstruction of the buildings. However, North Wind Site Services will review the current work
plans associated with the NWP remediation project and adapt plans to align with the
deconstruction project requirements for cutting and capping existing utilities, clearing and
grubbing, access route construction, etc., where impacted soils may be encountered. The
applicable deconstruction project plans will be submitted to USACE for review and approval.
The following is a list of plans and reports North Wind Site Services will develop specific to this
project and submit to USACE for review and approval:
• Preliminary, initial, and monthly schedules.
• Building Deconstruction Plan (PLN-60066-001).
• Deconstruction Summary Report.
• Site Operations Plan (PLN-60066-002) – This plan will include activities associated
with building deconstruction. Much of the same infrastructure utilized for the Soil OU
will be utilized by North Wind Site Services for deconstruction.
• APP/SSHP (PLN-60066-003) – This plan will address hazards associated with building
deconstruction activities in compliance with Engineer Manual (EM) 385-1-1
(USACE 2014).
• Contractor Quality Control Plan (CQCP) (PLN-60066-004) – This plan will address
quality control in a similar manner to that documented in the Soil OU CQCP (USACE
2020b) but will include deconstruction project résumés and submittal requirements.
• Uniform Federal Policy Quality Assurance Project Plan/Sampling and Analysis
Plan (UFP QAPP SAP; PLN-60066-005) – This plan will address deconstruction
QAPP/SAP activities, and is anticipated to be less detailed than the Soil OU UFP
QAPP/SAP (USACE 2020c).BUILDING DECONSTRUCTION PLAN FOR THE Identifier: PLN-60066-001
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• Regulatory Compliance Plan (PLN-60066-006) – This plan’s content will be very
similar to that in the Soil OU RCP (USACE 2016a) but will also include deconstruction-
specific regulations.
• Water Management Plan (PLN-60066-007) – This plan will address the specifics of
managing stormwater and wastewater associated with the deconstruction effort.
• Waste Management, Transportation, and Disposal Plan (PLN-60066-008) – This
plan will be based on the overall approach adopted by the project following the issuance
of the subcontracts for transportation and disposal. This process will include the
development of requests for proposal (RFPs) for each of these services and review and
approval by the USACE prior to issuance. After the RFPs are issued and proposals are
received, North Wind Site Services will evaluate the proposals and develop a consent
package for submission to and approval from the USACE.
• Contamination Control Plan (CCP) (PLN-60066-010) – The content of this plan will
be very similar to that of the Soil OU CCP (USACE 2018) since similar contaminants
(radiological, lead, and Be) are expected during building deconstruction. If additional
contamination sources are identified during hazards assessment, PLN-60066-010 will be
updated to address those hazards and mitigation practices.
• SWPPP (PLN-60066-012) – The plan will identify and implement controls associated
specifically with the work area around the buildings to be deconstructed. The anticipated
controls include silt fence, wattles, berms, and isolation of drains.
• Chronic Beryllium Disease Prevention Program (CBDPP) (PLN-60066-013) ‒ The
content of this plan will be very similar to that of the Soil OU CBDPP (USACE 2016b).
• Radiation Protection Plan (RPP) (PLN-60066-014) ‒ Due to the similar radiological
contaminants and control measures, the content of this plan will be very similar to that of
the Soil OU RPP (USACE 2020d).
• U.S. Environmental Protection Agency Tier 1 Qualified Facility Spill Prevention,
Control, and Countermeasure (SPCC) Plan (PLN-60066-015) – The content of this
plan will be very similar to that of the Soil OU SPCC Plan (USACE 2020e), but PLN-
60066-015 will identify responsible personnel and locations of equipment for the
building deconstruction project.
• Limited Operations Plan (COVID-19) (PLN-60066-019) ‒ The content of this plan
will be very similar to that of the Soil OU Limited Operations Plan (USACE 2020f).
5.2 Monitoring, Sampling, Testing, and Analysis (331XX02)
Monitoring, sampling, testing, and analysis have been identified as required for air, wastewater,
waste, and debris. The following provides a summary of these activities.You can also read
