Nuclear Metals

Nuclear Metals
contaminated site
Concord, MA

NRC-SDMP /Source Mtl. > 150Kg.
byproduct/ depleted uranium

The Nuclear Metals, Inc., also known as Starmet Corporation, site is located in Concord, Massachusetts. In 1958, NMI began operating a manufacturing facility that produced DU products, primarily as penetrators for armor piercing ammunition. Soil, sediment, and surface water samples taken historically and recently indicate that the holding basin, sphagnum bog, and cooling recharge pond all have elevated levels of DU.

The Nuclear Metals, Inc. (NMI) site, also known as the Starmet Corporation site, is located on a 46.4-acre parcel located at 2229 Main Street in Concord, Middlesex County, Massachusetts. The facility includes five interconnected buildings, a paved parking area, a sphagnum bog, a cooling water recharge pond, and a holding basin.

In 1958, NMI began operating a manufacturing facility on previously undeveloped land. Nuclear Metals, Inc. produced DU products, primarily as penetrators for armor piercing ammunition. NMI also manufactured metal powders for medical applications, photocopiers, and specialty metal products Disposal was executed via waste stream discharge. From 1958 to 1985, NMI discharged wastes to an unlined holding basin. Extrusion operations on depleted uranium produced rods with a thin layer of copper coating that was removed in a nitric acid pickling operation during which "small quantities" of copper and uranium were dissolved in the nitric acid. The spent nitric acid solution was collected, neutralized with a lime slurry, and discharged to the unlined, in-ground holding basin along with other wastes. Discharge to the holding basin ceased in 1985 when NMI began using an acid closed-loop recycling process.

NMI was renamed Starmet Corporation in 1997. In March 1997, the company's NRC license to handle source material (including depleted uranium, thorium, and thorium oxide) was transferred to the Massachusetts Department of Public Health, Radiation Control Program. The state collected groundwater samples and detected volatile organic compounds (VOCs) in NMI's supply well, previously used for drinking water. Further analytical results indicated that the groundwater beneath the property was contaminated with radionuclides (i.e., uranium and thorium), and other materials. In addition, a sphagnum bog on the property was also been sampled and has shown evidence of radionuclides. Soil, sediment, and surface water samples taken historically and recently indicated that the holding basin, sphagnum bog, and the cooling water recharge pond all have exhibited elevated levels of depleted uranium.

Cleanup Approach

In 1998, Starmet conducted a voluntary partial cleanup of contaminated soils under the Massachusetts Department of Environmental Protection (MADEP) oversight. The partial cleanup consisted of excavation and transportation off-site of approximately 8,000 cubic yards of soil contaminated with depleted uranium and copper. The cleanup halted in late 1998 when Starmet determined that the cleanup level set by MADEP could not be met without excavation of a significantly greater quantity of material. The site has since been listed on the National Priorities List; further evaluation of remaining contamination at the site will be addressed under EPA authority.

Response Action

A time-critical removal assessment was conducted to determine if buried drums on site contain hazardous material. Two areas containing buried drums and other laboratory equipment were located during the removal assessment: one in a fenced-in area adjacent to the holding basin and cooling water pond, and contains approximately 70 drums; the other, called the "old landfill" contains an unknown number of drums and laboratory equipment. A time-critical removal action was conducted which included: 1) installation of fencing around the "old landfill" area where buried drums are located; 2) re-grading and capping of the "old landfill" area; and 3) installation of a liner in the holding basin to eliminate fugitive dust and reduce the leaching of contaminated soils into the groundwater. Sampling and analysis of soils in the holding basin was conducted in September 2001 to fill data gaps in previous sampling efforts and to determine if data from past sampling efforts performed by Starmet were comparable to EPA data. In June 2002, EPA assumed the groundwater monitoring program previously performed by Starmet. During the

June 2002 sampling event, EPA also sampled sediment and surface water on-site and in the Assabet River. EPA sampled the groundwater monitoring wells again in July 2003 before turning site work over to Potentially Responsible Parties.



Progress and Current Status

Removal of 8,000 cubic yards of soil from the holding basin by Starmet under MADEP oversight has reduced the threat of potential exposure at the site. A time-critical removal action has been conducted to prevent the direct contact threat with the contaminated surface soils located in the "old landfill" area, and to reduce the infiltration of precipitation into the holding basin soils. EPA has installed a fence and warning signs around the perimeter of contaminated soils in the "old landfill" area, has capped the "old landfill" area; and, has installed a liner over the holding basin. In June 2003, EPA also negotiated an agreement with five potentially responsible parties including: U.S. Army, U.S. DOE, Whittaker Corporation, MONY Life Insurance Co., and Textron, Incorporated, for the performance of a Remedial Investigation/Feasibility Study (RI/FS), which includes the performance of an Engineering Evaluation and Cost Analysis (EE/CA). An EE/CA Approval Memorandum was signed on September 27, 2002, which authorizes the performance of an EE/CA in support of a Non Time-Critical Removal Action for the holding basin and buried drum areas. A lien has been recorded on the Starmet property at 2229 Main Street in Concord.

In May 2001, Starmet transported 1,700 drums containing depleted uranium from its South Carolina facility to the site, to facilitate its planned sale of that facility. Starmet also has approximately 2000 drums and other containers of depleted uranium wastes and approximately 100 drums of beryllium wastes stored at the site. Starmet is currently in violation of its MADPH radioactive materials license because it has failed to remove the stored drums of depleted uranium materials from the site and is therefore not allowed to process any radioactive material at the facility under their license. After Starmet indicated that it planned to cease operations or file for bankruptcy, the Commonwealth of Massachusetts obtained a preliminary injunction in state court in January 2002, requiring Starmet to continue to provide site security and necessary utilities. On March 15, 2002, the state court placed Starmet into temporary receivership. On or about March 18, 2002, Starmet abandoned the site property. The temporary receiver provided security and necessary utilities, with the assistance of MADPH, until March 25, 2002. Thereafter, MADPH began providing security at the site. Starmet filed for Chapter 11 bankruptcy protection on April 3, 2002, returned to the site, and continues to operate and provide site security. MADPH currently has funding available to provide security and necessary utilities if needed, through the financial assurance mechanism provided under Starmet’s radioactive materials license. If MADPH’s funding is exhausted and no other funding source is available, resulting in abandonment of the facility, then EPA may be required to address the security and utilities issues.

In April 2004, the state reached an agreement with the Army to remove the more than 3,000 drums of depleted uranium and other materials from within the facility. The state has procured a contractor for performance of the work, and shipments of drums and other material to the Envirocare waste disposal facility in Clive, Utah, began in September 2005. It is expected that the state removal work will be completed in spring 2006. In September 2004, EPA conditionally approved the RI/FS Work Plan submitted by de maximis, inc., the project coordinator for the private PRPs. Field work associated with the remedial investigation began in October 2004. In October 2004, under the supervision of U.S. Environmental Protection Agency, de maximis, inc., started an investigation of the Superfund Site to locate all contaminants and prepare a feasibility study of the Site cleanup. So far over 1300 samples of soil, sediment and water have been collected and analyzed. Since each sample is analyzed for a number of different contaminants, the data base contains over 300,000 records. Soil contamination has been found at several locations on the site. Contamination has also been located in the groundwater. The major contaminant is uranium. Polychlorinated biphenyls (PCBs) and volatile organic compounds are also

present. A number of other chemicals have been detected at lower concentrations. Analysis of data is being conducted to determine the extent of, and the risk from, the contamination.

Under a contract with MADEP, Envirocare Inc. is removing all identifiable radioactive and other waste material from the Starmet Plant. The material shipped so far to Clive, Utah, includes 1,315 drums of uranium tetrafluoride, 1,097 drums of a concrete and uranium mixture (conjoint) and 447 drums of other uranium waste. Approximately 250 drums of uranium tetrafluoride, 200 tons of uranium metal, and other miscellaneous waste remain to be shipped. The material is removed every working day in two or three Landstar Co. tractor trailers. The work was scheduled for completion by March 31, 2006. Removal of the radioactive material is required prior to starting the EPA investigation of the buildings and soil and water beneath them. The funding for the contract was provided by the U.S. Army.

In December 2004, de maximis, inc., under supervision of the EPA, removed from the ground between the Holding Basin and Cooling Water Recharge Pond a number of drums containing some uranium and beryllium waste, production tools and production materials, buried in 1967.

In April 2003 Weston Solutions Inc., under a contract with EPA, removed from the ground in the area of the Old Landfill (south of Bog) drums containing uranium and beryllium, more production tools and materials, then filled, graded and covered the area. Another phase of the plant cleanup, which will include the removal of all contaminated equipment, is anticipated after Starmet leaves the premises.



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