Nuclear Metals, Inc.

Superfund Site

Public Meeting

March 14, 2012

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Presentation Outline • Background

• Historic Regulatory Agency Involvement / Actions

– MADEQE/MassDEP

– EPA Time-Critical Removal Actions

• Comments by Town Representatives

– Concord Fire Department - Chief Mark Cotreau

– Citizens Research & Environmental Watch – Tim Rose

– 2229 Main Street Committee Chair - Pam Rockwell

• Current Activities under EPA authority

– Remedial Investigation / Feasibility Study (RI/FS)

– Non-Time-Critical Removal Action (NTCRA)

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Site Location USGS Quadrangle, Maynard, MA 1983

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Current Site Plan

Old Landfill Area

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Historical Site Activities • R&D activities included fundamental research in physical and

chemical metallurgy, fuel element development, and high temperature materials, primarily for AEC and the Department of Defense.

• Significant manufacturing operations included:

Fabricating depleted uranium (DU) metal into:

o Penetrators/armor-piercing munitions

oMedical shielding devices (radiography)

o Aircraft counterweights

Forming metal powders

Making beryllium and beryllium/aluminum alloy parts

• From 1958 to 1985, wastes were disposed of in the on-site “Holding Basin” and in other areas of the site

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Historic Regulatory Involvement • MADEQE, [now Massachusetts Department of Environmental

Protection (MassDEP)] got involved in 1980, when solvent contamination was found in an on-site water supply well.

• A variety of environmental studies were performed by NMI/Starmet and other entities between 1980 and 1998.

• With Army funding, Starmet excavated and disposed off-site 8,000 cubic yards of uranium-contaminated soil from the Holding Basin in 1997.

• Regulatory responsibility for Starmet’s licenses to possess radioactive materials was transferred from NRC to the MADPH-RCP (Mass Dept. of Public Health-Radiation Control Program) in 1997.

• In 2007, MassDEP performed removal action with Army funding to address drums of UF4 , DU metal, and other wastes.

• MADPH-RCP terminated the licenses to possess radioactive materials in November 2011.

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Depleted Uranium Tetrafluoride Drums

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EPA’s Activities • In July 2000, EPA proposed the Site for inclusion on the

National Priorities List (NPL). NMI was listed on the NPL in June 2001.

• Between March 2002 and April 2003, EPA conducted a time-critical removal action (TCRA) to reduce the potential for exposure by: – Capping the “old landfill” & installing a fence around the

area; – Lining the holding basin.

• In June 2003 EPA reached agreement with Settling Parties to conduct a Remedial Investigation / Feasibility Study (RI/FS) and Engineering Evaluation / Cost Analysis (EE/CA)

• Between January 2008 and September 2008, EPA conducted a second TCRA to remove hazardous and/or flammable materials from facility buildings

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Old Landfill Area – Before Cap

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Old Landfill Area – After Cap

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Holding Basin – Before Cap

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Holding Basin - After Cap

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2008 Time-Critical Removal Action

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2008 Time-Critical Removal Action

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Current Activities under EPA Authority Remedial Investigation / Feasibility Study (RI/FS)

• Initiated in 2003

• Evaluation of nature and extent of contamination, risks to human health and the environment, and options and costs to address unacceptable risks.

• “Study of everything outside the buildings, leading to overall Site remedy”

Non-Time-Critical Removal Action (NTCRA)

• Initiated in 2011

• Maintenance, then progressive removal of buildings contents and demolition of buildings, with capping of foundations.

• “Empty, then demolish the buildings.”

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Comments regarding the site work by: Chief Mark Cotreau, CFD

Tim Rose, CREW Pam Rockwell, Head of 2229 Main Street Committee

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Citizen’s Research and Environmental Watch (CREW)

• An independent citizen’s advocacy group founded in 1989 to oversee the safe operation at Nuclear Metals and now the safe and complete cleanup of the site.

• www.CREWConcord.org

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2229 Main Street Oversight Committee

• A volunteer Concord Town Committee formed by Town Meeting Article 51 in 2002 to monitor the process leading to the cleanup at Starmet, formerly Nuclear Metals, Inc. (NMI), a former defense contractor that is now a superfund site.

• Meets the first Tuesday of each month. • www.concordma.gov/pages/ConcordMA_BComm/2229Co

mmittee

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Remedial Investigation / Feasibility Study (RI/FS)

Evaluation of nature and extent of

contamination, risks to human health and the environment, and options and costs to address

unacceptable risks.

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RI/FS Timeline

Implemented Three Phases of Remedial Investigation (September 2004 – December 2009)

Human Health and Ecological Risk Assessments August 2009 - present

Remedial Investigation Report (~Summer 2012)

Feasibility Study Report (~Winter 2012)

Prepared Work Plans (September – December 2003) Finalized Work Plans (September 2004)

EPA Record of Decision (~Summer 2013)

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Remedial Investigation Field Work

• 52 monitoring wells installed (in addition to 80 pre-existing wells)

• Samples collected for laboratory analysis: – 225 groundwater – 81 surface water – 546 soil – 412 sediment

• Drums / materials buried in area between cooling water

pond and Holding Basin were excavated and disposed off-site.

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AOI 2 – Drum Excavation, Material Storage,

Packaging, & Off-Site Transportation and Disposal

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Poly Carboys and Drum

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Packaging of waste material from storage containers into 5-ton supersacks

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Loading supersacks into dump trailers

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Results of Remedial Investigation

• Extent of contamination in soil, sediment, surface water and groundwater delineated sufficiently to proceed with risk assessments.

• Surface soil and subsurface soil exceeding acceptable risk levels constrained to certain areas within Site boundary.

• Sediment exceeding acceptable risk levels constrained to portion of bog and cooling water pond.

• Groundwater contamination exceeding acceptable risk levels exists on-site and in defined area off-site.

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RI/FS – Next Steps • Finalize Risk Assessments

• Finalize and submit Remedial Investigation Report

• Prepare Feasibility Study Report

– Define “Preliminary Remediation Goals” (PRGs)

– Determine volumes of various media (soil, sediment, groundwater) exceeding PRGs within areas with unacceptable risk

– Evaluate remedial alternatives and costs for each affected media with unacceptable risk

• EPA prepares “Proposed Plan” that identifies overall remedy

• EPA issues “Record of Decision” that sets forth required remedy for Site.

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Public Involvement in RI/FS • Public Meetings will continue to be held at major project

junctures.

• CREW Concord and the 2229 Main Street Committee have been, and remain, closely involved in the process.

• The community will be able to review and comment on the proposed remedy prior to selection by EPA.

• Project Website at WWW.NMISite.Org

– Provides historic investigation reports

– Provides information on RI/FS activities

– Provides Geographic Information System (GIS) access to all RI sampling results (overlay of data on site map)

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Non-Time-Critical Removal Action (NTCRA)

( Building Demolition Project)

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Timeline Leading to NTCRA Project • In June 2006, EPA triggered preparation of Engineering

Evaluation / Cost Analysis (EE/CA) with respect to Starmet buildings

• Draft EE/CA submitted in November 2006, revised and finalized in February 2008

• Public meeting on EE/CA in April 2008

• In September 2008, EPA issued an Action Memorandum authorizing performance of Non-Time-Critical Removal Action (NTCRA) to empty and demolish buildings

• An Administrative Order on Consent (AOC) for the NTCRA became effective August 2011

• Last Starmet entity abandoned Site November 2, 2011

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Project Scope • Monitoring, access controls and site security • Building stabilization, removal and disposal of

hazardous and flammable and combustible materials • Removal and disposal of asbestos, universal waste,

and building contents • Demolish ~180,000 feet2 of buildings down to slabs • Fill voids and place a temporary cap over foundation. • Dispose of debris off-site at appropriately licensed

facilities • Post-removal site control (security and monitoring)

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NTCRA Timeline • Spring 2012 – prepare first set of “Construction Submittals”,

which will detail specific steps to remove and package building contents for off-site disposal, procure transportation and disposal contractors

• Summer / Fall 2012 – Proceed with removal of building contents

• Winter / Spring 2013 – Prepare second set of Construction Submittals, addressing removal of equipment, ductwork, etc from buildings

• Summer / Fall 2013 – Proceed with removal of equipment

• Winter / Spring 2014 – Prepare third set of Construction Submittals, addressing demolition of buildings and installation of temporary cap over foundation slabs

• Summer / Fall 2014 – Proceed with demolition and capping

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Site Plan

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Starmet Facility Buildings

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Completed Tasks • Interim NTCRA Work Plans submitted November 5,

2011, approved by EPA on December 19, 2011

• NTCRA Work Plans submitted on January 18, 2012

• Installed fencing / gate at street, placed “No Trespassing” signs around fence perimeter

• Secured facility (reinforced doors, changed locks)

• Shut down essentially all building electrical panels

• Setup Office Trailers

• Cleared brush from around buildings and perimeter fence

• Completed site familiarization training for CFD

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Completed Tasks (continued) • Disconnected and blanked high pressure natural gas

supply, installed new meter on low pressure natural gas supply

• Initiated inventory of building contents, with focus on flammable materials, gas cylinders, and chemicals

• Performed interior wipe and high volume air sampling

– Detected beryllium in most wipes, none in air samples

• Performed HEPA vacuuming and/or applied fixing agent in areas with significant surface contamination

• Initiated beryllium lymphocyte proliferation testing on project team, due to potential for exposure.

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Completed Tasks (continued)

• Installed five 2 Million BTU heating units and fuel supplies

– Running on portable generators pending installation of electrical supplies (near complete)

– Installed fans/ductwork to help circulate heat through out buildings

• Cleaned up metal debris/wood pallets outside building D (in courtyard area) – temporarily stored in roll off boxes

• Reinforced bottom areas of Butler Building B3 (walls were rotting wood)

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Completed Tasks (continued) • Installed electrical service , internet and phone lines to

trailers • Removed OSB Boards covering Bldg A windows • Removed air conditioner units from Bldg A windows and

blanked open windows with metal sheeting • Initiated actions in response to Fire Hazard Analysis

recommendations (access pathways, remove plastic sheeting, etc.)

• Completed design of internal lighting / power system • Initiated installation of lighting • Disconnected / Disabled Groundwater Supply Wells

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Work Trailers

Bottom Parking Lot prior to trailers

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Mobilized Heating Units

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Installed Heater (Butler B-4)

Before After

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Butler Building B3 Reinforcement (cont.)

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OSB Board Removal

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Air Conditioner removal

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Beryllium Area after clean up

Be Waste placed in white packs & moved to Rep area Starmet Drums moved into Rep Area

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Beryllium Area after Clean up

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Questions?

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NMI Site - Points of Contact

Title Name Phone # E-Mail Address

EPA Project Manager

Melissa Taylor

617 918 1310 Taylor.Melissag@epa.gov

EPA Community Relations

Kelsey O’Neil 617 918 1003 oneil.kelsey@epa.gov

MassDEP Project

Manager

Garry Waldeck 617 348 0417 Garry.Waldeck@state.ma.us

de maximis Project

Coordinator

Bruce Thompson 860 298 0541 brucet@demaximis.com

Project Website: WWW.NMISite.Org

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Areas of Soil or Sediment with Unacceptable Risk

Unacceptable Risk Area

(where remediation will

need to be evaluated in Feasibility

Study)

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Areas of Groundwater with Unacceptable Risk (VOCs)

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Area of Groundwater with Unacceptable Risk (DU)

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