Luckey

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The Luckey site is located at 21200 Luckey Road in Luckey, Ohio, approximately 35 kilometers (22 miles) southwest of Toledo. Structures at the site include large production, warehouse, and related buildings; transportation systems; and utility buildings. Several active and inactive lagoons and spoil areas are also present. Numerous open areas are vegetated, mostly with grasses and brush. The site encompasses approximately 16 hectares (40 acres).

FACILITY MISSION

Chemical and low-level radioactive contamination at the Luckey site consists of beryllium ore and production residues and traces of uranium. The estimated total waste volume is 26,400 cubic meters (34,500 cubic yards). The plants of the Magnesium Reduction Corporation, the Diamond Magnesium Company, and the Brush Beryllium Company formerly occupied the site. Contamination originated from beryllium and uranium processing operations conducted by Brush Beryllium under contract to the Atomic Energy Commission from 1942 to 1959.

According to estimates, the plant produced between 18,000 and 65,000 kilograms (40,000 and 144,000 pounds) of beryllium. Waste solutions and precipitated sludges from beryllium processing were impounded in three lagoons, formed by excavating the top layer of soil and using the soil to construct dikes. The Diamond Magnesium Company used the site to process magnesium and received approximately 900 metric tons (1,000 tons) of scrap steel contaminated with fission products. After the plant closed in 1959, hazardous sludge and contaminated soils from the lagoons were moved to a 3.4-hectare (8.5­acre) dike-enclosed landfill that was later capped, graded, and seeded. The facility changed ownership several times before it was transferred to the present owner, Urekch International Corporation. The site was designated for cleanup under FUSRAP in 1992.

The primary contaminants at the site (uranium, radium, and beryllium) have been detected in site soils at concentrations exceeding current background levels for the area. Current building and land use at the Luckey site presents no immediate short­term risk to site workers and the general public. The area surrounding the site consists of open farmland, and quarries are located south of the site. If future site use requires workers or members of the public to be present in contaminated areas for extended periods, the risk to these receptors could increase. Potential exposure pathways include inhalation and ingestion. The northern part of the property is currently leased for farming; extensive disturbance of the surface and subsurface soils for agricultural or industrial purposes could result in offsite migration of contaminants and could pose a risk to workers and the general public. However, the property owners currently have no plans to disturb the site other than to demolish a production building that was previously found to be uncontaminated.

FUTURE USE

After remediation, the site will be released for unrestricted use. This report assumes that use of the property will be Industrial.

ENVIRONMENTAL RESTORATION

Environmental restoration of the Luckey site will include disposition of approximately 26,400 cubic meters (34,500 cubic yards) of contaminated residues. The baseline assumes that cleanup will be conducted under the Comprehensive Environmental Response, Compensation and Liability Act protocol for remediation of low-level radioactive contamination at FUSRAP sites and the Atomic Energy Act of 1954, as amended. The environmental regulatory process will focus on compliance with the Comprehensive Environmental Response, Compensation, and Liability Act, and its implementing regulations. As required by the Comprehensive Environmental Response, Compensation, and Liability Act, the applicable or relevant and appropriate requirements of federal and state laws are incorporated in the development of remediation goals for the site.

Key regulators are Environmental Protection Agency Region V, the Ohio Environmental Protection Agency, and local governments, as appropriate. Other regulatory drivers may include the Clean Air Act, the Safe Drinking Water Act, and the National Pollutant Discharge Elimination System. Environmental documentation integrating Comprehensive Environmental Response, Compensation, and Liability Act and National Environmental Policy Act requirements is expected to include a Remedial Investigation/Feasibility Study-Environmental Impact Statement. The schedule for final cleanup depends on the issuance of a Record of Decision and funding.

ASSESSMENT

Field investigations at the Luckey site have included radiological surveys and sampling by the Department of Energy, the Ohio Environmental Protection Agency, and the Ohio Department of Health. All previous investigations identified onsite contamination. Preliminary radiological characterization in 1988 included a walkover surface gamma scan over a large portion of the property outdoors and sampling and analysis of water and surface and subsurface soil. The results indicated that site soils contain radium­226 and uranium­238, as well as high concentrations of beryllium. Because waste solutions and precipitated sludges from beryllium processing operations were impounded in the lagoons on the southern side of the plant, high concentrations of beryllium would be expected at these locations. Beryllium was also detected at high concentrations in soil samples from the northern side of the plant and the leased property north of the site. Final characterization to delineate the boundaries of the contaminated areas will take place immediately before remedial action begins.

REMEDIAL ACTION

In 1959, when the Atomic Energy Commission contracted Brush Wellman to close the plant, a 3.4-hectare (8.5­acre) dike-enclosed landfill was constructed in the northeastern corner of the property, and hazardous sludge and contaminated soil were moved from three lagoons to the landfill. Historical records indicate that the plant closure plan specified leveling the dikes on the empty lagoons and filling the lagoons with sufficient clay to bring the areas to ground level. The landfill area was then capped, graded, and seeded.

Site remediation under Department of Energy FUSRAP is in its initial planning stages. The scope of work for FY 1995 and FY 1996 consists of a preliminary characterization phase including analysis of historical records, site drawings, and site photographs to characterize site topography, drainage patterns, vegetation, and relationships to adjoining areas, and also to determine the focus of final characterization. Before remedial action begins, detailed radiological characterization of the surface and subsurface is recommended to define more precisely the extent of contamination.

Cleanup alternatives will be developed and evaluated as required under the Comprehensive Environmental Response, Compensation, and Liability Act and the National Environmental Policy Act. Interim removal actions will be initiated if needed to address contamination on any portion of the site before the Record of Decision is finalized, and environmental impacts will be documented in an Engineering Evaluation/Cost Analysis report and a categorical exclusion report as required by the National Environmental Policy Act. The selected cleanup option will be implemented after public review of the Remedial Investigation/Feasibility Study­Environmental Impact Statement and issuance of a Record of Decision.

The Department of Energy is currently considering an onsite remedy; however, the Comprehensive Environmental Response, Compensation, and Liability Act requires the Department to consider other alternatives. The scenario used for the Baseline Environmental Management Report cost estimate assumes excavation of contaminated soils and disposal by consolidation and onsite capping. The cost estimate assumes a total volume of 26,400 cubic meters (34,500 cubic yards) of chemical and low­level radioactive waste and transfer of responsibility for long­term surveillance and monitoring to the Grand Junction Projects Office in FY 2007. Given that the site has not yet been characterized, the estimate is based on consolidating all onsite waste materials on top of already contaminated subsurface pits, landfills, or lagoons, then adding an impermeable cap to minimize water infiltration. The size, number, and configuration of the onsite disposal cell(s) have not yet been determined.

FUNDING ESTIMATE

The following table presents estimated funding information for the Luckey site.