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Luckey FAQs

Luckey Site Frequently Asked Questions (FAQs)

Click on a question below to be taken to the answer.

A. General Site Questions

  1. Where is the Luckey Site? 
  2. How big is the site? 
  3. What is on the site? 
  4. Who owns the site? 
  5. When did the site become a Formerly Utilized Sites Remedial Action Program (FUSRAP) Site? 
  6. How did the area become contaminated with radioactivity? 
  7. What other organizations are involved in the cleanup? 
  8. What is the current status of the site? 
  9. What is a Baseline Risk Assessment and what do the results mean? 
  10. What is the cleanup going to cost and how long will it take to clean up the site? 
  11. How can I get more information about the Luckey Site? 

B. General Investigation Questions

  1. What would be the better alternative: to leave the contaminated soils in place because they pose no immediate health risk, or to remove them, even though doing so could create more problems? 
  2. Were tests done on the Troy Township Dump, and if so, what was found? 
  3. When you were testing the site, did you find any 55-gallon drums buried on site with radioactive contamination, and if so, could the contaminated metal that you found have been from those drums? 
  4. Is it true that a contractor may have removed material from the Luckey Site in the 1960’s to use as fill material on two residential properties in Luckey? Is the Corps planning on conducting an investigation on those properties? 
  5. When the contaminated material is dug up, what measures will the Corps take to ensure that beryllium dust and radioactive material does not become airborne and blow onto nearby residences? Will the Corps have to evacuate any residences? 
  6. Is the Federal government looking into holding Brush Wellman responsible for the contamination? 
  7. What uranium are you monitoring? 

C. Beryllium Questions

  1. Where has beryllium been located on the Luckey Site? 
  2. How do people become affected by beryllium? 
  3. What is the natural occurring beryllium level and what is the beryllium level at the site?
  4. Was the beryllium brought on the site or is it natural? 
  5. From where was the beryllium brought? 
  6. How deep was beryllium found at the site? 
  7. Is there a way to treat beryllium in soil on site? 
  8. Beryllium in water is not as bad as in the air, but you sampled in the water too. Is it a health hazard in water? 
  9. Have any of your wells shown beryllium contamination above the U.S. Environmental Protection Agency Maximum Contamination Level (MCL)? 
  10. Can beryllium be absorbed by the skin? 
  11. What are the long-term effects of exposure to FUSRAP-related contamination on the site (i.e., beryllium, lead, radium, thorium, and uranium), and how would someone know if he or she has been affected? 
  12. Can you contract berylliosis from touching beryllium? 
  13. Where can I get more information about berylliosis and the other diseases associated with beryllium exposure? 
  14. Does the USEPA list beryllium as a known carcinogen? 
  15. If the beryllium dust at the site becomes airborne, how far can it travel? Is there any potential exposure to neighboring residents? 

D. On-Site Worker Questions

  1. Were the employees who worked in the buildings where beryllium dust had been found in any danger and do they know beryllium dust was found where they worked? 
  2. If beryllium particles were in the dust at the Uretech facility, how long was the dust in the air? 

E. Building Questions

  1. Was air testing performed while the buildings were actively used? 
  2. During a previous meeting, you indicated that there was contaminated dust in the buildings. Why didn’t you address the buildings at that time? 
  3. Is there contamination around and under the buildings? According to the diagram (slide 15 of the July 27, 2010 presentation) there were soil borings done under the building? 
  4. Will this data lead you to test further under the buildings? 
  5. Doesn’t it make sense to take down the buildings? 
  6. Did you have any indication that there was contamination under the Annex building when it was demolished? 
  7. Have you now learned that the utilities are contaminated as well? 
  8. When are you planning on doing additional sampling? It is not on your timeline.
  9. Was additional air monitoring conducted during the latest round of sampling? If so, what do those results tell us about the potential for the community to be exposed to contamination that may be airborne from the site? 

F. Toussaint Creek Questions

  1. What are beryllium levels in the first 15 miles downstream at Toussaint Creek? 
  2. Does the level of contamination get progressively lower as you go further downstream at Toussaint Creek? 
  3. Is there any contamination upstream? 
  4. What happens to the beryllium-contaminants in Toussaint Creek when the creek floods? 
  5. Have you done any kind of study of the soils located within the 15 miles of the contaminated Toussaint Creek sediments? 
  6. If there are cows who drink the water in the contaminated portion of the creek every day, what are the chances of the beryllium contaminating the cow and passing the contamination along to humans if they eat the meat? 
  7. What are the health risks for children wading in the creek among the sediments? 
  8. What if the children have mosquito bites on their legs and feet? 
  9. Is there any other contamination in Toussaint Creek? Is lead in the creek? 

G. Quarry Questions

  1. During the late 1950’s and early 1960’s, a company called France Stone pumped water from the quarry, which affected local wells. Could the pumping have pushed more water and some of the contamination from the site to nearby residences? Were samples taken from the nearby rock quarry to ensure that no contamination was spread? 
  2. How far did you sample in the quarry; did you go all the way to the bottom? 
  3. If the water from the quarry isn’t affecting the well water in town, then why, when the water was emptied from the quarry, did the water levels in the town wells drop? 
  4. Is it logical to assume that contamination traveled further from the site when pumping of the quarry occurred? 
  5. If we are forced into a municipal water/sewer system, is the quarry OK to use? 

H. Groundwater Questions

  1. What is the natural flow of groundwater in the area of the Luckey FUSRAP Site? 
  2. When the Corps came to test groundwater depth in Luckey residential wells, did it test for beryllium? 
  3. How many residential wells have been tested, where were they and what were the results? 
  4. Is the Corps going to test the water in the Village of Luckey for beryllium? 
  5. The Luckey FUSRAP Site has two water supply wells. Which well is contaminated? 
  6. Do you do testing off the Luckey Site, such as across the street? 
  7. If the water quality in the wells is acceptable now, is there any chance that during or after the Luckey Site cleanup, the workers would disturb the groundwater flow, thereby contaminating the wells? 
  8. What well depth are you monitoring? 
  9. If my well has elevated levels of nitrate, would that have come from the site? 
  10. If a resident were to take independent tests of his or her wells and found beryllium, would he or she have to report it? 
  11. As a preventative measure, can a filtration system be put onto residents’ houses to filter the beryllium in the groundwater? 
  12. Can a neighboring resident of the site request that his or her well be tested? 
  13. Is the assessment and reporting of groundwater monitoring results to project stakeholders adequate? 
  14. Anychance that our village wells could get re-contaminated? We just put in a sewer system to make sure our wells are OK. Are you going to come back after your cleanup and tell us now your wells are contaminated and the Northwest Sewer District is going to have to hook us up? We already paid them.

I. Human Health Questions

  1. Has any kind of investigation been done regarding health effects in the elders? Wouldn’t this help you in your work? 

J. Security and Site Conditions

  1. Can the Corps do anything in regard to the deterioration of the Luckey Site buildings or site security due to the current property owner’s demolition activities? 

K. Remediation Questions

  1. Why doesn’t the Corps of Engineers establish and maintain a firm schedule for completing the cleanup of the Luckey Site? 
  2. Why doesn’t the Corps remediate all contamination at the Luckey Site which poses risk to human health and the environment instead of just contaminants associated with past activities related to the production of the atomic bomb?
  3. Wouldn’t it make sense from a funding standpoint to conduct a comprehensive cleanup removing all contamination under a Resource Conservation and Recovery Act (RCRA) cleanup action instead of conducting separate cleanups? 
  4. Is the Corps going to conduct air monitoring during remediation? 
  5. When you do get ready to clean up the site, will you take the buildings down first and then address the soils? Could you do this in the absence of the consent of the property owner? 
  6. Once you begin remediating the site, where will the contamination go? 
  7. Is the Corps going to continue to monitor the site for radioactivity after cleanup? 

L. Stimulus Questions

  1. Was a portion of the recent Federal Stimulus Funds for the Luckey Project used to conduct sampling beneath the Luckey Site buildings? 

A. General Site Questions

1. Where is the Luckey Site?

The Luckey Site is located at 21200 Luckey Road near the Village of Luckey, OH, about 22 miles southeast of Toledo. Luckey Road borders the site to the west, Gilbert Road to the south and abandoned railroad tracks to the east.
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2. How big is the site?

The Luckey Site covers approximately 40 acres.
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3. What is on the site?

Structures on the property that were formerly used in various industrial manufacturing processes include a large production building, utility buildings and a warehouse. Numerous open areas are covered with grasses and brush. Several areas were previously used to store byproducts from magnesium and beryllium processing.
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4. Who owns the site?

The United States owned the property between 1942 and 1961. Since that time there have been several owners who operated or leased the property for commercial/industrial purposes. In 2007, Hayes Lemmerz sold the site to Industrial Properties Recovery, LLC of Fremont, Ohio.
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5. When did the site become a Formerly Utilized Sites Remedial Action Program (FUSRAP) Site?

The U.S. Department of Energy (USDOE) determined the Luckey Site was an eligible FUSRAP property in September of 1992, when it was determined that some areas of the site had residual radioactivity, beryllium, and lead contamination exceeding criteria established by the USDOE.
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6. How did the area become contaminated with radioactivity?

In late 1951 and early 1952, when the site was being used to process beryllium, the United States Atomic Energy Commission (AEC) sent approximately 1,000 tons of radioactively contaminated scrap metal to the site for magnesium processing at the facility. The scrap metal, which contained radioactivity within guidelines at the time, was stored at the site, and never used for its intended purpose. Records also indicate that beryllium scrap from other AEC operations was sent to Luckey for reprocessing. Indications are that some of this scrap was contaminated with radioactivity. Site contaminants also include beryllium and lead derived from production wastes and sludges discharged to process lagoons and from the process ores stored onsite.
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7. What other organizations are involved in the cleanup?

Onsite contamination at the Luckey Site has been identified in surveys by the Ohio Environmental Protection Agency (OEPA), the Ohio Department of Health, and the U.S. Department of Energy. The U.S. Army Corps of Engineers manages the cleanup of FUSRAP-related contamination.
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8. What is the current status of the site?

With funds provided by the American Recovery and Reinvestment Act, the Corps completed a field investigation in March 2010 that included soil sampling and radiological, geophysical, and topographic surveys on the Luckey Site. Additional groundwater monitoring wells were also installed. The results of this work will provide the Corps with the information necessary to update the estimated cost associated with the cleanup outlined in the 2006 Record of Decision (ROD) for site soils and complete the remedial design. The remedial design, which is now being developed, will provide the detailed method required to implement the remedial action that was specified in the ROD. Groundwater monitoring is performed annually to provide baseline data for use during the implementation of the Groundwater ROD signed by the Corps in 2008.
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9. What is a Baseline Risk Assessment and what do the results mean?

The results of a Baseline Risk Assessment conducted by the Corps provide a basis for determining whether cleanup is warranted. This basis is documented in the Record of Decision, i.e., it was determined that a response action is needed to mitigate potential future human health risks associated with potential direct exposures to on-site soils and groundwater beneath the site. Other areas of the site (Toussaint Creek, the France Stone Quarry and the Troy Township Dump) were also evaluated but no adverse impacts to human health or the environment were found that warrant remedial action under FUSRAP.

The objectives of the baseline risk assessment were: 1) to estimate potential human health risks and environmental impacts associated with the Luckey Site; 2) to identify areas that do not pose unacceptable risks to human health or the environment, and thus require no further action; 3) to develop a list of constituents of concern (COCs) which contribute to unacceptable risks to human health or the environment; and 4) to develop risk-based concentrations (RBCs) and radionuclide action levels for the identified COCs to provide the basis of preliminary cleanup goals for the site. The baseline risk assessment considered exposure of the then-current site workers and potential future residents to contamination in on-site environmental media such as soils, sediments, surface water, and groundwater. The impacts to the environment (plants and animals) were also considered. The United States Environmental Protection Agency (USEPA) has established guidance for conducting baseline risk assessments and it has also compiled information regarding how toxic (harmful) each of the substances found at the Luckey Site can be to human health and the environment. The Corps followed the USEPA guidance and used USEPA toxicity criteria in assessing how the contamination on the site could impact human health and the environment.

The Corps determined that beryllium, lead, and radiological contamination from uranium, radium, and thorium at the site could pose risks above the USEPA acceptable risk range if the site were to be redeveloped for agricultural use in the future (which is the most reasonable future land use for the site), i.e., if someone were to use the site itself for farming. Direct, on-site, intensive and chronic exposure is needed for this risk to occur. Therefore, remedial action is warranted under FUSRAP.

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10. What is the cleanup going to cost and how long will it take to clean up the site?

The current cost estimate ranges from $86,765,000 to $596,260,000, and may take up to 15 years based on projected FUSRAP funding. The Corps is in the process of determining where the contamination ends in order to establish the limits of remediation and develop a more concise cost estimate. The current remediation cost estimate and cleanup duration could decrease after the limits of remediation are established.
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11. How can I get more information about the Luckey Site?

The Corps welcomes inquiries about the Luckey Site. Call toll-free at 1-800-833-6390 (Option 4), or e-mail us at fusrap@usace.army.mil. You can also ask to be included on the Luckey Site's mailing list, which will inform you about upcoming public meetings. Letters can be mailed to us at: U.S. Army Corps of Engineers, FUSRAP Public Information Center, 1776 Niagara St., Buffalo, NY 14207.
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B. General Investigation Questions

1. What would be the better alternative: to leave the contaminated soils in place because they pose no immediate health risk, or to remove them, even though doing so could create more problems?

After extensive investigations regarding the alternatives for the contamination on the Luckey Site, it was determined in the Soils Record of Decision, signed in 2006, that soils would be cleaned up to agricultural levels, which are the most stringent of the land-use scenarios used to develop cleanup goals. The constituents of concern (COCs) in soil consist of beryllium, lead, and radiological elements (radium, thorium, and uranium), which constitute FUSRAP contamination at the site. Soil remediation will be accomplished by excavating contaminated soils from the site and disposing of them in an appropriate off-site facility.

This alternative is considered to be most protective in the long-term, because all of the soils with FUSRAP contamination above the set cleanup goals will be permanently removed from the site. The Selected Remedy is protective of human health and the environment, complies with Federal and State requirements that are applicable or relevant and appropriate to the remedial action, and is cost effective.

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2. Were tests done on the Troy Township Dump, and if so, what was found?

At the Troy Township Dump, the Corps drilled soil borings and collected soil samples for laboratory analysis. No FUSRAP-related contamination was found at the Troy Township Dump.
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3. When you were testing the site, did you find any 55-gallon drums buried on site with radioactive contamination, and if so, could the contaminated metal that you found have been from those drums?

The Corps found remnants of drums in the northeast corner of the site, which is an area that is radioactively contaminated.
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4. Is it true that a contractor may have removed material from the Luckey Site in the 1960’s to use as fill material on two residential properties in Luckey? Is the Corps planning on conducting an investigation on those properties?

As a result of information provided by a former land developer, the Corps conducted site inspections in December 1999 at the two residential properties where fill material was placed. Based on results of the site inspections, the Corps conducted a more detailed investigation at one of the two properties and a portion of an adjacent property. The results of these investigations were shared with the owners of these private properties.
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5. When the contaminated material is dug up, what measures will the Corps take to ensure that beryllium dust and radioactive material does not become airborne and blow onto nearby residences? Will the Corps have to evacuate any residences?

A health and safety program will be implemented during any remediation that includes engineering controls such as wetting the work area to prevent the spread of dust. A program of perimeter air monitoring will also be utilized to monitor airborne dust. Operations involving soil movement will be stopped during high wind conditions to prevent the potential spread of contamination.
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6. Is the Federal government looking into holding Brush Wellman responsible for the contamination?

The Federal Government will determine which, if any, parties may have a legal obligation to pay at least a portion of the project costs and seek those costs where appropriate.
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7. What uranium are you monitoring?

We are monitoring the uranium isotopes 234, 235, and 238 in the soil and in the groundwater. These are all naturally occurring (not depleted or enriched) isotopes of uranium.
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C. Beryllium Questions

1. Where has beryllium been located on the Luckey Site?

Based on the Remedial Investigation conducted by the Corps, the largest volume of beryllium contamination is in the soil in the northeast portion of the site. Beryllium concentrations in sediments in Toussaint Creek are above background levels but below levels of concern for human health and the environment. Beryllium has also been detected above the drinking water standard in on-site groundwater monitoring wells, although it has not migrated to drinking water wells in the vicinity of the site. Additionally, beryllium has been detected in dust settled on building surfaces at the site.
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2. How do people become affected by beryllium?

The main hazard with beryllium is inhalation. Some people are more sensitive (“allergic”) to beryllium and can become sensitized if they come into skin contact with beryllium. The main health effect associated with beryllium is chronic beryllium disease, which affects the lungs and immune system. Beryllium is a human carcinogen if it’s inhaled. In addition, if beryllium is ingested in great enough quantities, beryllium has the potential to also pose adverse health effects to the digestive system.
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3. What is the natural occurring beryllium level and what is the beryllium level at the site?

In soil, the naturally occurring level is about 1 part per million (ppm). At the Luckey Site, the beryllium level in the soil varies greatly, from the western portion of the site where the average level is 6.6 ppm, to the north east region of the site, where the average level is 396 ppm. The area with the highest average level of beryllium is the north central portion of the site five feet below the surface, where one of the samples contained beryllium at 13,300 ppm.

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4. Was the beryllium brought on the site or is it natural?

Beryllium, in small amounts, is naturally occurring in soil, although beryl ore was brought to the Luckey Site from an outside source during the 1950’s.
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5. From where was the beryllium brought?

The beryl ore was originally brought from South America and Africa.
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6. How deep was beryllium found at the site?

Beryllium contamination varies from a depth of zero feet in some areas of the site (that is, at ground level) to 18 feet deep in the northeast portion of the site.
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7. Is there a way to treat beryllium in soil on site?

Yes. Solidification was evaluated in the Feasibility Study for the site but it was determined that the best remedial action for this site would be to excavate the contaminated soil and dispose of it in an off-site landfill that is suitable for this type of material.
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8. Beryllium in water is not as bad as in the air, but you sampled in the water too. Is it a health hazard in water?

The U.S. Environmental Protection Agency Maximum Contamination Level (MCL) for beryllium in water is 4 parts per billion (ppb). None of the privately owned wells in the village were found to have beryllium above this MCL.
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9. Have any of your wells shown beryllium contamination above the U.S. Environmental Protection Agency Maximum Contamination Level (MCL)?

Beryllium has been detected above the MCL in some shallow wells that are located on-site. The occurrence of beryllium above the MCL is not wide spread in groundwater because the element has a tendency to adhere to the soil.
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10. Can beryllium be absorbed by the skin?

The most recent health advisory published by the American Conference of Governmental Industrial Hygienists (ACGIH) (2009) indicates that skin exposure can cause sensitization to beryllium in certain people who are pre-disposed to be affected by beryllium. Sensitization can increase the chances that later inhalation of airborne beryllium can lead to chronic beryllium disease progression.
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11. What are the long-term effects of exposure to FUSRAP-related contamination on the site (i.e., beryllium, lead, radium, thorium, and uranium), and how would someone know if he or she has been affected?

The long-term effect of beryllium exposure could potentially be lung cancer or chronic beryllium disease (berylliosis). Some symptoms of beryllium exposure could be a dry cough, joint pain, shortness of breath and perhaps a skin rash. Specialized medical tests can indicate whether someone has been exposed to beryllium. The Corps suggests that you contact the local health department and/or your personal physician for further information regarding these tests.

Exposure to lead is most harmful for babies and young children. It can affect their neurological and intellectual development. Pregnant women who are exposed to lead contamination can pass the lead on to their fetuses. A blood test can detect elevated levels of lead.

The most common health effect from long-term exposure to radiation is the development of certain types of cancers. However, the levels of radioactive contamination at the Luckey Site are relatively low, and not as likely to cause adverse health effects as the levels of lead or beryllium are at the site.

The Agency for Toxic Substances and Disease Registry (ATSDR) is a good place to obtain public health fact sheets regarding these contaminants. http://www.atsdr.cdc.gov/substances/index.asp

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12. Can you contract berylliosis from touching beryllium?

From an initial touch of beryllium, you may develop sensitivity (akin to an allergy) to beryllium. This sensitization does not necessarily lead to berylliosis. Berylliosis (or chronic beryllium disease) is a disease of the lung, and for that to occur, you must inhale airborne beryllium dust into your lungs. The most recent health advisory published by the American Conference of Governmental Industrial Hygienists (2009) indicates that skin exposure can cause sensitization to beryllium in certain people who are pre-disposed to be affected by beryllium. Sensitization can increase the chances that later inhalation of airborne beryllium will lead to chronic beryllium disease progression.
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13. Where can I get more information about berylliosis and the other diseases associated with beryllium exposure?

A good source of information is the Agency for Toxic Substances and Disease Registry (ATSDR), which is part of the U.S. Department of Health and Human Services. The ATSDR has created a “frequently asked questions” sheet and a public health statement on beryllium. To receive this information, contact the ATSDR directly at: 1-800-232-4636, or by email at ATSDRIC@cdc.gov. This information may also be accessed on the web at http://www.atsdr.cdc.gov/toxfaqs/tf.asp?id=184&tid=33

Another source of information on beryllium can be obtained from the Occupational Safety and Health Administration (OSHA). Their beryllium website is http://www.osha.gov/dts/hib/hib_data/hib19990902.html

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14. Does the USEPA list beryllium as a known carcinogen?

Beryllium is considered a carcinogen through the inhalation pathway. Many years ago, the United States Environmental Protection Agency (USEPA) listed beryllium as a carcinogen for the ingestion pathway, but as time went by, more studies were conducted that showed animals did not get cancer from eating beryllium. Because of those findings, the USEPA amended this classification and dropped beryllium into Class BI, “probable human carcinogen.” This means that there is adequate data to prove that beryllium causes cancer in animals, but the data is too limited to adequately prove that beryllium causes cancer in humans via ingestion. However, the American Conference of Governmental Industrial Hygienists (ACGIH), in their most recent health advisory published for beryllium, (2009), designated beryllium as a confirmed human carcinogen (Class A1).
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15. If the beryllium dust at the site becomes airborne, how far can it travel? Is there any potential exposure to neighboring residents?

It depends on the force that is used to launch a dust particle into the air. However, many variables can affect travel distance such as wind speed and particle size. During remediation, the Corps will implement engineering controls such as wetting for dust suppression, to ensure the protection of human health and the environment.
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D. On-Site Worker Questions

1. Were the employees who worked in the buildings where beryllium dust had been found in any danger and do they know beryllium dust was found where they worked?

Based on the Corps’ test results obtained at the time the buildings were utilized, the employees working there at that time were not in immediate danger under normal workday operations. Beryllium detected by the Corps inside the site buildings was settled on surfaces. The primary hazard associated with beryllium is airborne dust that can be inhaled. This could occur if settled dust becomes airborne due to activities such as:
  • Disruptive maintenance work,
  • Remodeling, or
  • Demolition work.

In short, if the beryllium dust was not disturbed, it was not airborne and could not be inhaled, so the hazard was likely not present.

While Uretech was still operating the buildings, the Corps and Uretech provided test results to the employees through employee briefings and fact sheets. The Corps also advised the factory management against the types of activities listed above unless proper precautions were used. Under OSHA(1) regulations the employer must ensure health and safety requirements are satisfied to protect its workers.

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2. If beryllium particles were in the dust at the Uretech facility, how long was the dust in the air?

There are many factors that determine the amount of time a particular particle is in the air, which include particle size, gravity, static charge, and air currents.

The Corps conducted studies that included air monitoring at the site in 1998 and 1999. In a breathing zone, which consists of a sphere three feet in diameter around a person’s head, the Corps determined that beryllium in site dust particles was well below OSHA regulations in place at that time. All 8-hour air monitoring results showed time weighted averages(2) to be less than one half of the then current OSHA 8-hour permissible exposure levels.

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(1) OSHA stands for the Occupational Safety and Health Administration, which is part of the U.S. Department of Labor. OSHA sets the standards for safety in the workplace. It sets the Code of Federal Regulations that determines at what concentration a contaminant can exist in the workplace and still be considered safe. If the standard is exceeded, then the contaminant may have some negative impacts on human health.
(2) A time-weighted average is calculated by multiplying the air concentrations obtained over the sampling period by its time. These are called sampling events, which are added together and divided by the total time to obtain an average exposure for the day.


E. Building Questions

1. Was air testing performed while the buildings were actively used?

Yes. During the remedial investigation conducted by the Corps (1998 – 2000), several different air samples were taken in and around the buildings. (Please see question 35 for more information). The results are summarized in the Remedial Investigation Report (2000), which is available on-line and in the administrative record at the Luckey Library.
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2. During a previous meeting, you indicated that there was contaminated dust in the buildings. Why didn’t you address the buildings at that time?

Contamination within the buildings was identified by the Corps during their remedial investigation. The report of the remedial investigation was published in 2000, and is available on-line and in the administrative record at the Luckey Library. No evidence of a contaminant release to the environment was identified at that time. Manufacturing operations were ongoing at that time and the Corps notified the facility owner/operator of our findings. Worker safety is regulated by the Occupational Health and Safety Administration (OSHA) and is the responsibility of the owner/operator.
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3. Is there contamination around and under the buildings? According to the diagram (slide 15 of the July 27, 2010 presentation) there were soil borings done under the building?

The former production annex building was demolished by the site owner, which enabled the Corps to collect soil samples from beneath the building slab. Preliminary results for beryllium and radiological contamination were presented in Slides 15 and 16, respectively, of the July 27, 2010 presentation. The field data report with validated results is scheduled for public release in early 2011.
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4. Will this data lead you to test further under the buildings?

Should the validated results from soil samples collected beneath the annex confirm a potential source of contamination beneath the building(s) that has not been previously identified, samples would be collected as required beneath the building(s) during site remediation to ensure cleanup of FUSRAP-related contaminants at the site that is consistent with the ROD and protective of human health and the environment.
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5. Doesn’t it make sense to take down the buildings?

Recent sampling indicates contamination under the slab of the former Annex building. As part of the Remedial Design phase, the Corps will consider the results of the most recent sampling of soils beneath the buildings as well as the current status of the buildings, and ensure that the remedial action is designed to be fully protective of human health and the environment, based on our authority under the established Record of Decision.
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6. Did you have any indication that there was contamination under the Annex building when it was demolished?

The Corps was not aware that beryllium contamination may have been present under the building. We had no knowledge that the owner was going to demolish the building and therefore, no pre-demolition sampling was conducted.
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7. Have you now learned that the utilities are contaminated as well?

Based on results of the recent (2010 – 2011) investigation conducted by the Corps, beryllium and radiological contamination above the site cleanup goals was identified in soils surrounding a buried utility line located south of the production building. In addition, beryllium contamination was identified above the site cleanup goals in two manholes (in a location where utility lines are buried) located north of the buildings.
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8. When are you planning on doing additional sampling? It is not on your timeline.

Additional soil sampling may be done at the time of remediation. Before the site is formally closed-out, we will perform a final status survey of the site to demonstrate that the remedial action presented in the Record of Decision has been fully implemented and the protective cleanup goals have been met. Groundwater sampling occurs on an annual basis to ensure the protection of human health and the environment.
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9. Was additional air monitoring conducted during the latest round of sampling? If so, what do those results tell us about the potential for the community to be exposed to contamination that may be airborne from the site?

Yes, air samples were taken from around the perimeter of the site, and also from the breathing zone of site workers (both contractors and USACE employees) during the sampling activities. Those air monitoring results will be included as part of the soil sampling report when it is finalized and published in early 2011.
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F. Toussaint Creek Questions

1. What are beryllium levels in the first 15 miles downstream at Toussaint Creek?

In the first mile downstream, the highest concentration of beryllium detected was 223 ppm. After a distance of one mile, concentrations were less than 15 ppm. At 13 miles downstream, the concentrations were about the same as naturally occurring levels upstream of the site.
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2. Does the level of contamination get progressively lower as you go further downstream at Toussaint Creek?

No. The beryllium levels decrease downstream but not uniformly or gradually.

Downstream beryllium concentrations varied from 15.9 parts per million (ppm) to 0.92 ppm (composite samples) and from 14.3 ppm to 0.77 ppm (grab samples). The highest concentrations (15.9/14.3 ppm) occur immediately downstream of a wastewater treatment plant & sludge beds. Downstream of this location, the concentrations vary from approximately 5.5 ppm to <1 ppm.

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3. Is there any contamination upstream?

Beryllium was identified in sediments upstream of the site and was comparable to background levels.
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4. What happens to the beryllium-contaminants in Toussaint Creek when the creek floods?

Sediments that contain beryllium may be transported downstream during flood events. However, beryllium is present in relatively low concentrations (i.e. less than 15 ppm) in nearly all of the Toussaint Creek sediment samples that were collected downstream of the site. These concentrations are below the USEPA Region 9 screening level for beryllium, which is 150 ppm.
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5. Have you done any kind of study of the soils located within the 15 miles of the contaminated Toussaint Creek sediments?

The Corps has collected 38 samples from creek meander bends (curves in the creek where sediment may have been deposited along the banks). The samples contained beryllium at concentrations of 1.4 parts per million (ppm) to 90 ppm. While these concentrations are above naturally occurring concentrations, they are below the USEPA Region 9 screening level (beryllium screening levels are developed to identify exposure concentrations that require further investigation) of 150 ppm.
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6. If there are cows who drink the water in the contaminated portion of the creek every day, what are the chances of the beryllium contaminating the cow and passing the contamination along to humans if they eat the meat?

Beryllium ingestion studies and models performed on animals, such as hamsters and rats, have concluded that beryllium doesn’t stay in the animal or move into the muscle tissue. Rather, it passes through the digestive system. Therefore, there is no evidence to suggest that if cattle were to ingest beryllium contaminated sediments by drinking water from Toussaint Creek, the resulting meat or milk of the animal would be affected.
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7. What are the health risks for children wading in the creek among the sediments?

The Corps conducted a study and determined that the risks for beryllium exposure from children wading or even drinking water from the creek are very low. To gather more information in answering this question, a full health risk assessment was completed for an adolescent (7-18 year old) wading in the creek. The complete evaluation may be found in Chapter 6 (Baseline Human Health Risk Assessment) of the Remedial Investigation Report, which is part of the Administrative Record File for the Luckey FUSRAP Site, located in the Luckey Public Library.

USEPA guidelines were used to develop this health risk assessment. The Corps assumed that children might wade in the portion of the creek where beryllium contamination has been detected. Very conservative exposure assumptions were used that involved a child playing in the creek for one hour per day, 52 days per year for 10 years. The results showed that exposure to sediments in the creek pose a very small risk of contracting cancer; there were no non-cancer risks. These results are within acceptable risk limits established by the USEPA.

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8. What if the children have mosquito bites on their legs and feet?

There are no risks above the acceptable cancer and health risk limits established by the U.S. Environmental Protection Agency (USEPA) due to FUSRAP-related contamination to children in the creek, even if they have open sores and cuts on their legs and feet. The Corps performed an additional evaluation where it was assumed that children would periodically wade in the creek with about 16 cuts or mosquito bites on their legs and feet. Even with this assumption, there was not a large increase in risk presented by the contaminants in the creek water and sediments. Risks remain very small and would be within the range of acceptable cancer risks established by the USEPA.
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9. Is there any other contamination in Toussaint Creek? Is lead in the creek?

Although lead was detected in several of the sediment samples at concentrations above naturally occurring concentrations, the only contaminant contributing significantly to risk is an organic compound, benzo[a]pyrene. This compound is not a FUSRAP related contaminant.
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G. Quarry Questions

1. During the late 1950’s and early 1960’s, a company called France Stone pumped water from the quarry, which affected local wells. Could the pumping have pushed more water and some of the contamination from the site to nearby residences? Were samples taken from the nearby rock quarry to ensure that no contamination was spread?

Pumping of water from the quarry reportedly occurred from the 1940’s to the early 1970’s. The quarry operation very likely influenced the flow of ground water at that time and probably caused water in the vicinity of the quarry to flow toward the quarry. Sediment and surface water samples were collected from the quarry as part of the Corps’ remedial investigation and no FUSRAP-related contaminants were found.
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2. How far did you sample in the quarry; did you go all the way to the bottom?

A sediment sample was collected from the bottom of the quarry, which is about 70 feet deep. Water samples were collected from different depths in the quarry.
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3. If the water from the quarry isn’t affecting the well water in town, then why, when the water was emptied from the quarry, did the water levels in the town wells drop?

When the quarry operation occurred, water was pumped from the quarry, which would have lowered the groundwater levels in the area. However, the quarry is no longer in operation and groundwater levels are not being affected.
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4. Is it logical to assume that contamination traveled further from the site when pumping of the quarry occurred?

The Corps’ test results provide no evidence to suggest that contamination traveled further from the site when pumping of the quarry occurred.
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5. If we are forced into a municipal water/sewer system, is the quarry OK to use?

The quarry was tested for FUSRAP-related contaminants only. Additional water quality tests should be performed prior to determining suitability for municipal use.
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H. Groundwater Questions

1. What is the natural flow of groundwater in the area of the Luckey FUSRAP Site?

Groundwater in the vicinity of the site flows in a northerly and northwesterly direction.
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2. When the Corps came to test groundwater depth in Luckey residential wells, did it test for beryllium?

Groundwater depths were measured in residential wells to calibrate a numerical groundwater flow model that was developed for the site and to determine groundwater flow direction in the vicinity of the site. Groundwater samples were taken from area residential wells and tested for beryllium. The following questions and answers discuss the beryllium results.
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3. How many residential wells have been tested, where were they and what were the results?

The Corps has collected tap water samples from three residential wells; two of the wells are directly north of the site and one is adjacent to the west side of the site. The initial tap water sample collected at the first residence north of the site in July 1998 contained beryllium at a concentration of 7.7 parts per billion (ppb), which exceeded the U.S. Environmental Protection Agency Maximum Concentration Level (MCL) of 4 ppb. However, beryllium was not detected in 6 of the 8 subsequent samples and was detected at concentrations less than the average naturally occurring concentration in the remaining two samples. In 8 quarterly samples collected from the second residence north of the site, beryllium was detected in one of the samples at a concentration less than the average naturally occurring concentration, but was not detected in the remaining 7 samples. Tap water samples were collected in 1998 and 1999 from the residence located west of the site and beryllium was not detected in either sample. The Corps has attempted to collect tap water samples from two residences and a church directly east of the site in 1998, but was refused access. More residences were sampled in the Village of Luckey; please see the following question and answer.
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4. Is the Corps going to test the water in the Village of Luckey for beryllium?

The Corps’ investigations indicate groundwater flows north from the Village toward the site, so testing of the Village water was not warranted. In other words, groundwater in the village is “upstream” of the groundwater at the site. However, based on input provided by the public at the September 19, 2000 public meeting, the Corps and Wood County Health Department conducted limited sampling of tap water in the Village of Luckey and at several residences along Gilbert, Luckey and Garling roads, as well as several locations on Lemoyne Road near Toussaint Creek. Beryllium was not detected in the tap water of any of the sampled residences.
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5. The Luckey FUSRAP Site has two water supply wells. Which well is contaminated?

The west well, which is currently not in use, contains beryllium between 9 and 13 parts per billion (ppb), which exceeds the U.S. Environmental Protection Agency Maximum Concentration Level of 4 ppb.
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6. Do you do testing off the Luckey Site, such as across the street?

The Corps maintains monitoring wells on the site and north of the site in a farm field. The off-site wells are located downgradient of the site and would detect contaminants migrating from the site via groundwater. FUSRAP contamination has not been detected in these wells.

Monitoring wells contaminated with beryllium, lead, and total uranium are located on the site in discrete areas and do not constitute a single plume of contaminated groundwater. Since 2000, groundwater monitoring results have remained consistent, which indicates that these contaminants are not leaching from soil or fill and are not migrating through the groundwater. Groundwater movement beneath the site is very slow due to the fine textured soils (i.e. clay and silt) and low gradient (shallow slope) that are present. In addition, the FUSRAP contaminants have a high tendency to adhere to the fine textured soil particles. Additional information about the Corps’ annual groundwater program and results is available on the web at www.lrb.usace.army.mil/fusrap/luckey.

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7. If the water quality in the wells is acceptable now, is there any chance that during or after the Luckey Site cleanup, the workers would disturb the groundwater flow, thereby contaminating the wells?

During remediation, contaminated soil will be removed and groundwater quality is expected to improve afterwards. A groundwater monitoring program will be implemented after the soil remediation is complete, and will continue at each impacted well until the groundwater is returned to safe levels. The groundwater monitoring program is identified in the Groundwater ROD (2008), which is also available on the Corps’ website.
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8. What well depth are you monitoring?

The Corps monitors groundwater that is present in the soil and bedrock. The sampled well depths range from approximately 12 to 60 feet.
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9. If my well has elevated levels of nitrate, would that have come from the site?

The Corps did not test for Nitrate, as it is not a FUSRAP related contaminant.
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10. If a resident were to take independent tests of his or her wells and found beryllium, would he or she have to report it?

Please contact your local health department or the Ohio Environmental Protection Agency for answers to such questions.
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11. As a preventative measure, can a filtration system be put onto residents’ houses to filter the beryllium in the groundwater?

Please contact your local health department or the Ohio Environmental Protection Agency for answers to such questions.
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12. Can a neighboring resident of the site request that his or her well be tested?

Please contact the Wood County Health Department.
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13. Is the assessment and reporting of groundwater monitoring results to project stakeholders adequate?

Yes, since issuing the Luckey Soil and Groundwater Record of Decisions, the Corps has been monitoring groundwater conditions at the site and reporting the results annually to project stakeholders. The results are also available on our website. The results from the groundwater sampling events are routinely evaluated in conjunction with data obtained from previous years to assess changes in groundwater conditions. This analysis has determined that groundwater conditions have not changed over time and that FUSRAP contaminants exceeding the U.S. Environmental Protection Agency Maximum Concentration Level remain confined to the site.
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14. Any chance that our village wells could get re-contaminated? We just put in a sewer system to make sure our wells are OK. Are you going to come back after your cleanup and tell us now your wells are contaminated and the Northwest Sewer District is going to have to hook us up? We already paid them.

The village wells are located upgradient of the site and sewage contamination is different than the FUSRAP contamination (beryllium, thorium, radium, and uranium) on the Luckey Site. The FUSRAP contaminant concentrations in site groundwater are only slightly above the U.S. Environmental Protection Agency Maximum Concentration Levels and the contamination is confined to the site. The Corps will continue to monitor groundwater to ensure that the FUSRAP contaminants are contained and not moving off-site.
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I. Human Health Questions

1. Has any kind of investigation been done regarding health effects in the elders? Wouldn’t this help you in your work?

The Corps does not conduct health studies. The Corps models potential human health impacts that could occur if someone were to be hypothetically exposed to site contamination, to determine if the site needs to be remediated. The Corps evaluates worse case (“reasonable maximum”) potential exposures, not actual exposures to contamination, to make sure that our clean-up is the most protective possible.

Questions regarding health studies should be directed to your local health department. Further assistance may be obtained from the Agency for Toxic Substances and Disease Registry (ATSDR) which is part of the Department of Health and Human Services and Centers for Disease Control. Information regarding petitioning for Public Health Assessments from ATSDR is available on its website (http://www.atsdr.cdc.gov/COM/petition.html) and excerpted here. You may also write to:

ATSDR Petition Coordinator
ATSDR/DHAC/OD
4770 Buford Hwy, NE (F-59)
Atlanta, GA 30341

In your letter, you must include the following information:

  • your name, address, and phone number
  • the name of the group you represent, if any
  • the name, location, and description of the facility or release
  • information you have about people's exposure to a toxic substance
  • a request that ATSDR perform a Public Health Assessment

Additional information that is helpful to ATSDR, but not required, includes:

  • any other information about the facility or release-such as the chemical you are concerned about, the amount in the environment now or in the past, or the parties you believe may be responsible
  • exposure pathways
  • how many people might be exposed-particularly how many older persons and children
  • other government agencies you have contacted or which have investigated already
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J. Security and Site Conditions

1. Can the Corps do anything in regard to the deterioration of the Luckey Site buildings or site security due to the current property owner’s demolition activities?

The Luckey Site is privately owned property. The Corps’ responsibility, as set forth in the RODs, is to remediate contaminated soil resulting from work performed at the site for the Atomic Energy Commission. The Corps is not authorized to maintain the site or structures on the site. The property owner is responsible for maintenance of the buildings and control of site access to safeguard the public.

The Corps does not have authority to direct the property owner to maintain the site. Local and state regulatory agencies may have enforcement authority over the property owner and may be responsible to ensure the property owner maintains the site in a manner that is protective of human health and the environment in accordance with state and local law.

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K. Remediation Questions

1. Why doesn’t the Corps of Engineers establish and maintain a firm schedule for completing the cleanup of the Luckey Site?

The Corps’ work at the site is funded by Congress through FUSRAP. Each year Congress allocates a certain amount of funding to the program, to be divided among FUSRAP projects across the nation. The annual budget for the Luckey Site is determined within the dictates of the funding needs throughout the program in concert with the funding needs of the other FUSRAP sites. Funding constraints of the program require the Corps to complete ongoing remedial actions before committing to new ones. Therefore, funding to initiate remedial activities at the Luckey Site is contingent upon the progress of remediation at the other FUSRAP sites. Currently, the Corps is scheduled to award a remediation contract and develop work plans in 2014 and mobilize to the Luckey Site to begin remedial action in 2015.
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2. Why doesn’t the Corps remediate all contamination at the Luckey Site which poses risk to human health and the environment instead of just contaminants associated with past activities related to the production of the atomic bomb?

FUSRAP is a cleanup program created by the Federal Government to address a specific type of radiological and chemical contamination associated with past activities of the Manhattan Engineer District (MED) and the Atomic Energy Commission (AEC). The program is only authorized and funded to address FUSRAP-related contamination at FUSRAP sites. The Corps has been tasked by Congress to remediate the FUSRAP-related materials at the Luckey Site which includes beryllium, lead, and the radionuclides (radium, thorium and uranium) in site soils and groundwater. The Corps cannot address any other contamination at the site. The private site owner and federal and state environmental regulatory agencies (such as the U.S. Environmental Protection Agency and Ohio Environmental Protection Agency) may be responsible for any other non-FUSRAP contamination on the site.
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3. Wouldn’t it make sense from a funding standpoint to conduct a comprehensive cleanup removing all contamination under a Resource Conservation and Recovery Act (RCRA) cleanup action instead of conducting separate cleanups?

Pursuant to federal law, the Corps is only authorized to perform remediation of FUSRAP-related contaminants. The Corps would coordinate and cooperate to the extent practicable with any parties who undertake remediation of non-FUSRAP contaminants that may be present at the Luckey Site. Any attempt at a comprehensive cleanup would require action by the U.S. Environmental Protection Agency (USEPA) or Ohio Environmental Protection Agency (OEPA) pursuant to their respective authorities.
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4. Is the Corps going to conduct air monitoring during remediation?

Air monitoring will be conducted while remedial activities are being performed at the site. Prior to initiating remedial activities, the public will be informed on the specifics of the air monitoring program at the site.
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5. When you do get ready to clean up the site, will you take the buildings down first and then address the soils? Could you do this in the absence of the consent of the property owner?

Presently, the answer is no. However, because recent sampling of soil beneath floor slabs has identified contamination above cleanup goals, the Corps is currently evaluating the best course of action regarding the buildings. The Corps may condemn property for the benefit of the public if it determines such action is necessary.
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6. Once you begin remediating the site, where will the contamination go?

The contaminated waste will be shipped to an approved hazardous waste disposal facility located off-site.
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7. Is the Corps going to continue to monitor the site for radioactivity after cleanup?

The need for monitoring will not be necessary upon full completion of the selected remedy of complete excavation and disposal of the constituents of concern from the Luckey Site. Before the site is formally closed-out, we will perform a final status survey of the site to demonstrate that the remedial action presented in the Record of Decision has been fully implemented and the protective cleanup goals have been met. Groundwater monitoring will continue after the soil remedial action is completed. After site closure activities are complete, the Corps will turn the site over to the U.S. Department of Energy’s Office of Legacy Management.
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L. Stimulus Questions

1. Was a portion of the recent Federal Stimulus Funds for the Luckey Project used to conduct sampling beneath the Luckey Site buildings?

Yes. The intent of the ARRA funding as designated for this project was to move forward the remediation process as defined in the Record of Decisions (ROD) issued for the Luckey Site. The 2009 ARRA funding contains a provision for field investigation activities with the stated purpose of, “fully funding a Remedial Field Characterization Program to improve confidence in (remediation) volumes and costs.” Although the field sampling program did not include sampling beneath the buildings, sampling was performed in the vicinity of the existing buildings, including under the floor slab of the former Annex building demolished by the site owner (see response to Question #38).
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