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February 17, 2020 - The U. S. Army Corps of Engineers, Baltimore District, has initiated a five-year review for the W.R. Grace Curtis Bay Formerly Utilized Sites Remedial Action Program (FUSRAP) Site, Baltimore, Maryland. 

The review process involves an evaluation of the risk posed by residual radioactivity remaining at Building 23, which is associated with monazite sand processing by the property owner to extract the radioactive element thorium under a contract with the Atomic Energy Commission in the 1950’s. As a result of the processing operations, low levels of radioactive contamination remain in Building 23.  The selected remedy to address residual radioactivity at Building 23 provides for either decontamination or removal of areas within the southwest quadrant of Building 23 that had been impacted with FUSRAP radionuclides is documented further in a Record of Decision dated 2005. An amendment to the 2005 Record of Decision is currently being coordinated with stakeholders to propose the complete demolition of the southwest quadrant of Building 23. 

The methods, findings, and conclusions of the review will be documented in a Five-Year Review Report. The report will also identify issues found during the review, if any, and propose recommendations to address them.  The final Five-Year Review report is anticipated by September 2020 and will be made available to the public.

Click here for the full public notice.

W.R. Grace FUSRAP Project Overview

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Since 2001, USACE has conducted a multi-phase remedial investigation (RI), developed a Feasibility Study (FS), Proposed Remedial Action Plan (PRAP), and Record of Decision (ROD) for Building 23 to address areas which are impacted by residual radioactivity from thorium-processing operations of monazite sands at the facility in the late 1950s under contract with the AEC.  The remedy for the southwest quadrant of Building 23 identified in the ROD, dated May 2005, is “Decontamination with Removal to Industrial Use Levels.”  From 2009-2013, USACE initiated remedial design/remedial action activities in accordance with the 2005 ROD, which included removal of equipment and building components with the highest reported radiological activity.  Based on the persistence of low levels of residual radiological activity exceeding remedial goals on building surfaces following two phases of remediation and the difficulty of decontamination due to the complexity of the building interior, USACE and W.R. Grace reevaluated whether the remedy selected in the April 2005 ROD could be successfully completed as planned.  The selected remedy was evaluated in comparison to an alternative to demolish the southwest quadrant of Building 23. 

To support the reevaluation of a demolition alternative, in comparison to the remedy selected in the 2005 ROD, a conceptual design for demolition of the southwest quadrant of Building 23 was conducted.  Pre-design investigations, including engineering surveys, geotechnical and hydrologic investigations, and additional radiological delineation of soil, were conducted in 2017 and the results were included in the conceptual design.  Based on the design activities, the partial demolition of Building 23 (demolition of the southwest quadrant) was determined to be technically feasible.  In addition, based on the results of the additional radiological delineation, which indicated exceedances of the industrial use criteria at depths not previously identified and at locations in close proximity to facility infrastructure, it was determined that excavation to remove all impacted soil (following demolition of the southwest quadrant) would not be feasible; as such, Land Use Controls (LUCs) for soil will be required.

The project team, in consultation with the Maryland Department of the Environment (MDE) and W.R. Grace, is proposing an updated remedy to address the threat to human health and/or the environment created by the presence of residual radiological activity in the southwest portion of Building 23 of the W.R. Grace, Curtis Bay Facility. The USACE prepared an Amended PRAP in 2019 to evaluate alternatives.  The USACE is currently preparing a ROD Amendment where the preferred alternative is “Demolition of Southwest Quadrant of Building 23”. This alternative will minimize risk by removing the majority of 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 in the long term when compared to the other alternatives assessed as part of the 2019 Amended PRAP.  

Upon completion of the demolition of the southwest quadrant of Building 23, a Final Status Survey (FSS) will be conducted consistent with MARSSIM requirements to verify that remedial goals are met for the remaining building components and ensure that the remedial action objective has been achieved.  LUCs would be used to ensure that proper actions are taken any time the soil beneath the southwest quadrant of Building 23 is exposed, and five-year reviews by the government would be required. 

The W.R. Grace Formerly Utilized Sites Remedial Action Program (FUSRAP) site is located at 5500 Chemical Road in Curtis Bay, Maryland.  W.R. Grace conducted thorium-processing operations of monazite sands at the facility in the late 1950s under contract with the U.S. Atomic Energy Commission (AEC).  Title to the monazite sand and materials extracted from the monazite remained with the government during the performance of the work under the contract.  Isotopic components of raw monazite sand include uranium-238 (238U) and thorium-232 (232Th) and their decay progeny.  The processing ended in the spring of 1957.  The thorium-processing operations were conducted in the southwest quadrant of Building 23, a five-story industrial area with multiple doorways, openings, and rooms.  As a consequence of the processing, building components and certain equipment in the southwest quadrant of Building 23 exhibit residual radiological activity.  Soils beneath the southwest quadrant are also affected.  Wastes from the processing were disposed of in the Radioactive Waste Disposal Area (RWDA) where residual radioactive contamination remaining in soils.  The Department of Energy (DOE) identified the W.R. Grace site for inclusion in the FUSRAP in 1984.  USACE is the lead Federal agency for selection of the necessary and appropriate response actions for the W.R. Grace Curtis Bay site. Work is being conducted in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) process and incorporates USACE and Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) guidelines. In 2008, USACE and W.R. Grace & Co. entered into a Settlement Agreement to address the FUSRAP Matters (as defined in the agreement but including remedial actions to address contamination in the southwest quadrant of Building 23). Due to site complexities (e.g., active manufacturing facility, settlement agreement, facility is within the Baltimore Critical Area, etc.), extensive coordination is required between USACE and the property owner as well as other stakeholders to achieve project objectives.  

Since 2000, USACE has conducted a multi-phase remedial investigation (RI), and developed a Feasibility Study (FS), Proposed Remedial Action Plan (PRAP), and Record of Decision (ROD) for the RWDA to address soils (estimated to be >75,000 CY) which are impacted by residual radioactivity from thorium-processing operations of monazite sands at the facility in the late 1950s under contract with the AEC.  The remedy selected in the ROD, dated June 2011, for the RWDA site at the W.R. Grace Curtis Bay facility is ”Excavation, Segregation, and Off-Site Disposal” . An FFS will be conducted of open excavations (prior to backfilling and covering) and surrounding areas in accordance with MARSSIM. The selected remedy provides for removal and off-site disposal of contaminated soils to meet the remedial goals identified in the ROD. Start of site remediation activities at the RWDA is dependent on the availability of funding in the national program and the completion of the Building 23 remedial action.