Overview of Site History

The W.R. Grace Formerly Utilized Sites Remedial Action Program (FUSRAP) site is located at 5500 Chemical Road in Curtis Bay, Maryland in the highly industrialized Hawkins Point neighborhood of south Baltimore. W.R. Grace owns and operates a chemical manufacturing plant on the property, which is under 24-hour surveillance and mostly surrounded by a chain link fence to the south and east. Curtis Bay borders the property to the north and Curtis Creek to the west. The nearest residential neighborhood is approximately 1 mile to the northwest, on the other side of Curtis Creek.

Map showing W.R. Grace FUSRAP project, including Building 23 and the Radioactive Waste Disposal Area, or RWDA.

Under contract with the U.S. Atomic Energy Commission (AEC), a W.R. Grace predecessor company processed monazite sand at the Curtis Bay facility from 1956 to 1957. Monazite sand is a mineral ore that was shipped to the facility from overseas. The contract was for the extraction of thorium, a naturally occurring radioactive metal. Raw monazite sand contains the isotopes thorium-232 (232Th), uranium-238 (238U), and their decay progeny.  

Operations for AEC were conducted in the southwest quadrant of Building 23, a large, five-story building that is still in use by W.R. Grace. As a result of the monazite sand processing, parts of the building and equipment exhibit residual radiological activity. Soils underneath the building were also affected. Waste material from the operations were disposed of in the Radioactive Waste Disposal Area (RWDA) on the eastern part of the W.R. Grace property. Residual radioactive contamination exists in the RWDA soils. 

In 1984, the U.S. Department of Energy (DOE) added the W.R. Grace property to the FUSRAP list for cleanup. USACE is now the lead Federal agency for response actions for the program. Work is being conducted in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and incorporates USACE and Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) guidelines.

USACE and W.R. Grace & Co. entered into a Settlement Agreement to address the FUSRAP Matters (as defined in the agreement, including cleanup of the southwest quadrant of Building 23 and the RWDA). Due to W.R. Grace’s ongoing manufacturing operations and conditions of the settlement agreement, extensive coordination is required between USACE and the property owner. In addition, USACE and W.R. Grace coordinate cleanup activities with the Maryland Department of the Environment (MDE), Air and Radiation Administration.

Building 23 Investigation & Cleanup History

From 2001-2005, USACE took the following actions for the southwest quadrant of Building 23: conducted a multi-phase remedial investigation (RI) to determine nature and extent of contamination; developed a Feasibility Study (FS) to evaluate cleanup alternatives; issued a Proposed Remedial Action Plan (PRAP) for public comment; and finalized a Record of Decision (ROD) to document the selected remedy for cleanup. These CERCLA phases were conducted to address the residual radioactivity in the southwest quadrant of the building. The remedy identified in the 2005 ROD is “Decontamination with Removal to Industrial Use Levels.” Responses to public comments received on the PRAP are included in the ROD. 

Map of the W R Grace FUSRAP Project Site

From 2009-2013, USACE developed the remedial design and conducted part of the cleanup inside the building, including the removal of equipment and building components with the highest radiological activity. However, based on the persistence of low levels of radioactivity above cleanup goals on certain building surfaces, USACE and W.R. Grace reevaluated the selected remedy.

Engineering surveys, geotechnical and hydrologic investigations, and soil sampling were conducted in 2017. Based on these activities and discussions between USACE and W.R. Grace, the partial demolition of Building 23 was determined to be technically feasible. The soil sampling showed higher levels of radioactivity deeper underground than previously identified (greater than 16 feet below grade).  Because the contaminated soil is close to facility infrastructure including other active parts of Building 23, it was determined that it would not be feasible to remove the soil. Therefore, long-term controls for the management of the soil, if disturbed, will be required.

In consultation with MDE and W.R. Grace, USACE prepared an Amended PRAP in 2019 to summarize the reevaluation of cleanup alternatives and document the new preferred alternative, “Demolition of Southwest Quadrant of Building 23.” A ROD Amendment was finalized in 2020 after a public comment period and is available in the Project Documents section of this website. The selected remedy includes demolition of the southwest quadrant along with land use controls, which will be the long-term controls for the management of contaminated soil. This alternative will minimize risk by removing building components that are contaminated with radioactivity at the site. This alternative is technically feasible and is considered the most protective of human health and the environment when compared to the other alternatives assessed. The remedial design for the demolition of the southwest quadrant is currently in progress. The demolition will be conducted by carefully “deconstructing” the building, with extensive environmental monitoring during work activities, to ensure the safety of workers and the public.

In 2021, as part of CERCLA requirements, USACE completed a Five-Year Review for the remedial action at Building 23. The review process involved an evaluation of the risk posed by residual radioactivity remaining at Building 23. The Five-Year Review concluded that the demolition remedy for Building 23 will be protective of human health and the environment upon completion, and that appropriate site controls are in place in the interim. The Five-Year Review is available in the Project Documents section of this website.

Currently, the remedial action for Building 23 is on hold, pending the resolution of litigation involving W.R. Grace and a third party. When the litigation is resolved, USACE will facilitate W.R. Grace’s procurement of new contracts and oversee the implementation of the remedial design. Upon completion of the demolition of the southwest quadrant of Building 23, a Final Status Survey will be conducted using MARSSIM guidelines to verify that remedial goals are met for the remaining building components and ensure that the remedial action objective has been achieved. Land use controls will be used to ensure that proper actions are taken any time the soil beneath the southwest quadrant of Building 23 is exposed, and ongoing Five-Year Reviews will be conducted by the Government. 

Radioactive Waste Disposal Area (RWDA) Investigation History and Status

Between 1999 and 2011, USACE took the following actions for the RWDA: conducted a multi-phase remedial investigation (RI) inside the fenced in area identified as the RWDA; conducted supplemental sampling outside RWDA to the south (adjacent boundary areas); developed a Feasibility Study (FS); issued a Proposed Remedial Action Plan (PRAP); and finalized a Record of Decision (ROD) to address contaminated soils. There is no known pathway for public exposure to the contaminated soils, as the property is secured.  The remedy selected in the 2011 ROD is excavation, segregation, and off-site disposal of contaminated soil for both the RWDA and adjacent boundary areas. Responses to public comments received on the PRAP are included in the ROD. The ROD and PRAP are available in the Project Documents section of this website.  The selected remedy provides for removal and off-site disposal of contaminated soils to meet the remedial goals identified in the ROD.

In 2015, additional contamination was found outside the RWDA to the east, indicating that FUSRAP waste material was possibly spread in many areas outside the fence line. USACE and W.R. Grace subsequently held multiple technical discussions and partnering meetings to discuss these findings and the impact on the impending remedial action. Consensus was reached to conduct an additional pre-design investigation (PDI) to determine the full extent of contamination and more accurately quantify the amount of FUSRAP material requiring remediation.

Currently, USACE is preparing the work plans for the PDI, which is planned for 2024. A remedial design will then be performed to describe the procedures and requirements for the cleanup. Following implementation of the excavation, segregation, and removal of contaminated soil, a Final Status Survey of the open excavations will be conducted in accordance with MARSSIM, prior to backfilling and covering, to confirm that the remedial goals have been achieved.