Excitement was in the air of Building 6 on the Buffalo District reservation the afternoon of Apr.16, 2018. The Formerly Utilized Sites Remedial Action Program (FUSRAP) project delivery team for a site in Luckey, Ohio was waiting to hear from the field that the Phase 1 cleanup began. At 4:08 p.m. the first photo was taken; the Luckey site contractor, North Wind-Portage, had just started excavating soil contaminated with beryllium, lead, radium-226, thorium-230, uranium-234 and uranium-238 from the Phase 1 cleanup area of the site.
“I've waited 18 years for this day," said Marc Graham, project health physicist, as he took the photo from outside the site fence line.
FUSRAP was initiated in 1974 to identify, investigate, and, if necessary, clean up or control sites throughout the U.S. contaminated as a result of Manhattan Engineer District or early Atomic Energy Commission activities. Congress transferred administration and execution of FUSRAP cleanups from the U.S. Department of Energy to the Corps of Engineers in Oct. 1997.
The Corps of Engineers issued the notice to proceed on the $100 million remediation contract on Oct. 15, 2015. The contractor spent the next two years preparing 12 different work plans that the project delivery team meticulously reviewed, commented on, and approved. These plans govern the cleanup as it proceeds. In late Sept. 2016, the Buffalo District awarded a task order to establish site infrastructure and mobilize the equipment needed to start the cleanup. Required pre-remediation air sampling, to determine the amount of contaminants naturally occurring in the area, began in Feb. 2017. Ninety days after the start of background monitoring, site mobilization and infrastructure set up began. Office trailers, an on-site laboratory, a water treatment facility, and a soil sorter were brought to the site and set up. Electrical, water and sewer connections were established and concrete pads were poured.
Excavation will proceed slowly to ensure that all systems and procedures (environmental/health and safety monitoring, contamination control, waste transportation [on-site], stockpiling, soil sorting, wastewater treatment, loading of roll-off containers, and sampling and segregating below criteria soils), are working properly. Adjustments will be made to these systems and procedures, as necessary, to ensure the remediation is conducted in a safe and efficient manner. The excavated material is being stockpiled until enough material is available to begin the soil sorting process. The cleanup work will be performed in five phases. The Corps estimates that there are approximately 14,000 cubic yards of contaminated soil to be addressed in the Phase 1 area and 110,000 cubic yards of contaminated soil to be addressed at the site.
The U.S. Army Corps of Engineers’ priorities during the Luckey site cleanup are the protection of human health and the environment and the safety of the workers and the community. Due to the presence of beryllium contamination at the site, extreme measures are being implemented to prevent exposure to this unique element. Beryllium is a brittle, light weight metal which is used in a wide variety of applications in the aerospace, nuclear and manufacturing industries. Beryllium is also a highly toxic substance that can result in acute and chronic lung damage, and is a known carcinogen. Chronic beryllium disease (CBD) occurs when people inhale beryllium dust or fumes and can take anywhere from a few months to 30 years to develop after their first exposure. The disease is treatable but not curable, and can sometimes cause fatal scarring of the lungs. Approximately 2% of all people exposed to beryllium develop CBD. In 2013, the Buffalo District developed a CBD Prevention Program—the first one in the U.S. Army Corps of Engineers, to protect Corps of Engineers workers from the hazards of beryllium.
Preventing the spread of contamination during the soil cleanup is key. The team performing the cleanup will use dust control measures during the excavation, sorting and stockpiling site soils to ensure FUSRAP-contaminated soils do not become airborne during cleanup activities. These measures include spraying water on the roads, applying a fixative to the soil stockpiles, using a water spray to dampen the materials as they are being excavated, and using several machines to spray a mist on the materials as they are moving through the soil sorter conveyors. An on-site weather station will enable work stoppage as necessary due to bad weather conditions.
The area where the cleanup is occurring (the exclusion zone) will have limited access. Workers entering the area will be wearing protective clothing and personal breathing zone air monitors. When the workers exit the work area, their protective clothing will be removed and disposed of. Workers will then shower to ensure they are not inadvertently carrying contamination with them off site. Surfaces in the on-site office trailers will be routinely sampled to verify that contamination has not spread.
Air sampling in and around the excavation areas will be conducted during active excavation, and continuously around the perimeter of the site, to monitor for dust and potential airborne FUSRAP contamination. Real-time airborne dust monitors are set to go off at an action level that is below the level that would present a problem so that work can stop, the cause of the alarm can be determined, and controls can be implemented to alleviate the condition before a problem occurs. If an alarm goes off on the continuously operating perimeter air monitors during non-working hours, a notification system is established. The site contractor will receive the notification and will be able to call workers in as necessary to investigate and alleviate the condition.
Materials that are being transported for disposal will be loaded into flexible bulk packages within roll-off containers. A tarp will also be placed over the containers before they leave the site. Soil transportation vehicles and other equipment will be surveyed prior to leaving the site to ensure that they are not inadvertently carrying FUSRAP contamination off site. Each truck driver will be briefed on the transportation route, speed limits and procedures to be followed at the disposal facility before the truck leaves the site.
The total estimated cost (contractor and government cost combined) for the cleanup is up to $244 million. Soils contaminated with FUSRAP-related materials will be disposed of offsite at the US Ecology, Inc., disposal facility in Belleville, Michigan, which is permitted to accept these materials. Transportation of FUSRAP-related wastes to the Michigan facility is currently scheduled to begin during May 2018.