PB98-964112
EPA 541-R98-158
March 1999
EPA Superfund
Record of Decision:
H & K Sales
(Belding Warehouse)
Belding, MI
11/4/1997
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 5
RECORD OF DECISION
Selected Remedial Alternative
for the
H&K Sales (Belding Warehouse) Superfund Site
Belding, Ionia County, Michigan
November 1997
-------
CONTENTS
Section Page
I . Declaration ii
II. Administrative Record Index iii
III. State Letter of Concurrence vi
IV. Glossary viii
i
V. Decision Summary 1
A. Site Location and Description 1
Figure 1 2
Figure 2 3
B. Site History and Enforcement Activities 4
C. Summary of Previous Site Status and Risks 5
Table 1 6
D. Highlights of Community Participation 9
E. Scope and Role of Early Response Action 10
F. Summary of Current Site Status 12
Table 2 13
G. Applicable or Relevant and Appropriate Requirements
for Radiation Sites 13
H. Site Returned to Owner 15
VI. Responsiveness Summary 16
-i-
-------
DECLARATION
SELECTED REMEDIAL ALTERNATIVE
FOR THE
H&K Sales (Belding Warehouse) Site
fielding, Ionia County, Michigan
Statement of Basis and Purpose
This decision document presents the selected remedial action ("No
Further Action") for the H&K Sales site, also known as the
Belding Warehouse site, Belding, Ionia County, Michigan, which
was chosen in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act of
1986 (SARA), and, to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan. This decision
is based on the administrative record for the site. The attached
index identifies the items that comprise the administrative
record upon which the determination (that no further remedial
action is necessary) is based.
Description of the Selected Remedy
No further remedial action is necessary at the H&K Sales site.
Declaration Statement
It has been determined that no further remedial action is
necessary at the H&K Sales site because the conduct of a non-time
critical removal action eliminated the existing and potential
risks to human health and the environment. Therefore, the site
now qualifies for inclusion on the Construction Completion List
and it is now eligible for deletion from the National Priorities
List.
The five-year review or other follow-up monitoring will not apply
or not be required at this site because no hazardous substances
remain on-site above health-based levels.
State Concurrence
The State of Michigan is expected to concur with the selected
remedy. The Letter of Concurrence will be attached to this
Record of Decision upon receipt.
///V/r-7
William E. Muno, Director ' Date
Superfund Division
-11-
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
REMOVAL ACTION
ADMINISTRATIVE RECORD
FOR
BELDING WAREHOUSE SITE
(AKA: H&K SALES SITE)
BELDING. IONIA COUNTY, MICHIGAN
ORIGINAL
JUNE 11, 1996
NO. DATE
1 01/31/95
2 06/29/95
3 10/31/95
01/00/96
02/29/96
04/00/96
04/00/96
AUTHOR
Michigan
Department
of Public
Health
U.S. Department
of Health and
Human Services/
Agency for
Toxic Substances
and Disease
Registry
Watt, F.,
Michigan
Department
of Public
Health
U.S. EPA
U.S. EPA
RECIPIENT
Smith, E.,
U.S. EPA
U.S. EPA
U.S. EPA
TITLE/DESCRIPTION
Radioactive Contam-
ination at Belding,
Michigan
Public Health Advisory
for Aircraft Components
(D&L Sales), Benton
Harbor, MI and H&K
Sales, Belding MI
Letter re: Requesting
Applicable or Relevant
and Appropriate Require-
ments (ARARs) w/Attach-
ments
Belding Warehouse
Radiation Site Emergency
Contingency Plan
Environmental News
Release: EPA Begins
Investigations at
Michigan Radiation Sites
Proposed Plan: Belding
Warehouse Superfund Site
Engineering Evaluation/
Cost Analysis: Belding
Warehouse Superfund Site
22
51
111
-------
Belding Warehouse AR
UPDATE fll
JULY 12, 1996
DATE
07/16/96
AUTHOR
Adler, K.,
U.S. EPA
RECIPIENT
Muno, W.,
U.S. EPA
TITLE/DESCRIPTION PAGES
Action Memorandum: 91
Request for Approval of
a Time-Critical Removal
Action and a Consistency
Exemption to the $2
Million Statutory Limit
at the Belding Warehouse
Site w/Attachments A-I
IV
-------
Belding Warehouse AR
UPDATE #2
OCTOBER 16, 1997
NO. DATE
1 OB/26/97
09/19/97
AUTHOR
U.S. EPA/
OERR
RECIPIENT
U.S. EPA
2 09/00/97 U.S. EPA
3 09/16/97 U.S. EPA
Public
Public
Concerned
Citizen
U.S. EPA
TITLE/DESCRIPTION PAGES
Memorandum Forwarding 19
Attached Superfund
Radiation Guidance
Documents
Proposed Plan for the 8
Belding Warehouse
Superfund Site
Transcript of September 40
16, 1997 Public Meeting
and Hearing re: the
Belding Warehouse
Superfund Site
Public Comment Sheet re: 2
the Proposed Plan for
the Belding Warehouse
Site
00/00/00
MDEQ
U.S. EPA
6 00/00/00 U.S. EPA
Public
Letter re-. MDEQ's
Concurrence with the
Record of Decision for
the Belding Warehouse
Superfund site (PENDING)
Record of Decision for
the Belding Warehouse
Superfund Site (PENDING)
-------
STATE OF MICHIGAN
JOHN ENGLER, Governor
DEPARTMENT OF ENVIRONMENTAL QUALITY
HOLLISTER BUILDING. PO BOX 30473. LANSING Ml 48909-7973
INTERNET, www deq stale mi us
RUSSELL J. HARDING, Director
December 2, 1997
Mr. William E. Muno
Director, Superfund Division
United States Environmental Protection Agency
Region 5
77 West Jackson Boulevard (S-6J)
Chicago, Illinois 60604-3590
Dear Mr. Muno:
The Michigan Department of Environmental Quality (MDEQ), has reviewed the proposed Record of
Decision (ROD) received October 20, 1997, for the H & K Sales (Belding Warehouse) Superfund site in
Ionia County, Michigan. We are pleased to inform you we concur with the proposal for No Further
Action outlined in the ROD for the site.
This remedy meets state cleanup requirements for radiologically impacted materials and allows for the
building to be returned to the owner for unrestricted use. The United States Environmental Protection
Agency (EPA) non-time critical removal action has removed all radioactive material off-site, disposed of
the material in appropriate regulated facilities outside of the state of Michigan, and completed
decontamination of the warehouse building. Thus, no additional response activities are necessary to
address this Superfund site.
The MDEQ appreciates the expeditious removal action your agency conducted at this site. If you have
any questions, please contact Mr. Brady Boyce, Superfund Section, Environmental Response Division, at
517-373-4824, or you may contact me.
Sincerelv,
Russell J. Harding
Director
517-373-7917
cc: Mr. Kevin Adler, EPA
Mr. Robert Skowronek, MDEQ
Mr. Alan J. Howard, MDEQ
Ms. Claudia L.S. Kerbawy, MDEQ
Dr. George Carpenter, MDEQ
Mr. Brady Boyce, MDEQ/H & K Sales File
EOPOlOOe
(Rev 10/96)
-------
MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY
INTEROFFICE COMMUNICATION
October 16, 1997
TO:
FROM:
Brady Boyce
Superfund Section
Environmental Response Division
Robert Skowronek, Chief
Radioactive Materials and Standards Unit
Radiological Protection Section
Drinking Water and Radiological Health Division
SUBJECT: Belding Warehouse Superfund Site
We have completed our confirmatory radiation survey of the Belding Warehouse Superfund Site.
Drinking Water and Radiological Protection Section staff performed a radiation survey of
Warehouse 1, Warehouse 2, Warehouse 3, the radiological laboratory room, the sample
packaging room, the metal warehouse attached to Warehouse 1, and the loading dock areas
outside Warehouse 1. The site contractor decontaminated several small areas that exceeded the
release limits. Our resurvey of these areas showed mat the decontamination was successful. We
will forward a copy of the onnfirmatmy survey report when it is completed.
We have completed a review of the data collected by the site contractor during the final
verification survey at the Belding Warehouse Superfund Site. Based on this review and our
confirmatory survey, we conclude that the decontamination oi the facility has been completed.
The facility can be released for unrestricted use.
-------
Glossary
H&K Sales (Belding Warehouse) Site
Belding, Ionia County, Michigan
The following terms or expressions are used throughout this
document (they are highlighted in bold the first time they appear
in the main text) :
Alpha-particle = a = A positively charged particle consisting of
2 protons and 2 neutrons (a helium nucleus) ejected by
radioactive decay of certain elements such as Radium-226. Alpha
particles rapidly lose energy when passing through matter and
thus do not penetrate very far (a sheet of paper can stop them),
although the damage they can cause to body tissues is very great .
Alpha particles are usually completely absorbed by the outer dead
layer of human skin and thus alpha particle emitters are
generally not considered to be a hazard outside of the body:
However, alpha emitters can cause very great damage if inhaled or
ingested into the body.
Beta particle = B = A charged particle consisting of an electron
or positron ejected by radioactive decay of certain elements such
as Radium-228. Beta particles move much faster than alpha
particles and thus can penetrate farther into matter although
they are less damaging over equally travelled distances. Some
beta particles can penetrate the skin to cause cell damage, but
in general beta emitters are only considered to be a hazard if
they are inhaled or ingested into the body. A layer of clothing
or aluminum foil can stop beta particles.
cpm = Counts per minute = the number of radioactive emissions
counted by a radiation measuring instrument in one minute.
Curie = Ci = A unit of measurement concerning radioactive
elements which corresponds to 3.7 E+10 radioactive
disintegrations per second. Although different "radioactive
elements may decay at different rates, one Curie of Radium-226
corresponds to approximately 1 gram of Radium-226.
Daughter product = Decay product = An atomic species (such as
another element) that is the product of radioactive decay of the
parent atom. Radon-222 is a daughter product of Radium-226.
Dose = The amount of radiation absorbed by the body, internally
and externally, from any given sources of radiation.
dpm = Disintegrations per minute = the number of nuclear
disintegrations per minute from a given radioactive material.
-Vlll-
-------
Gamma rays = = Non-particulate, .high-energy radiation emitted
by radioactive decay of certain elements such as Radium-226 and
Potassium-40. Gamma rays have no charge nor mass and are very
penetrating: they can easily pass completely through the human
body or be absorbed by cell tissue causing great damage. Several
feet of concrete or a few inches of lead may be required to stop
gamma rays.
gram = g = Metric unit of mass and weight measurement (about
28.3 grams equals one ounce).
liter = L = Metric unit of volume measurement (about 3.78 liters
equals one gallon).
micro = \i = One millionth (1 E-6) part of; 1 microCurie (/*Ci) is
one millionth of a Curie or about one millionth of a gram of
Radium-226.
mill! = m = One thousandth (1 E-3) part of; 1 milliCurie (mCi) is
one thousandth of a Curie or about one thousandth of a gram of
Radium-226.
nano = n = One billionth (1 E-9) part of; 1 nanoCurie (nCi) is
one billionth of a Curie or about one billionth of a gram of
Radium-226.
pico = p = One trillionth (1 E-12) part of; 1 picoCurie (pCi) is
one trillionth of a Curie or about one trillionth of a gram of
Radium-226.
Radiation = Particles or energy rays produced by the radioactive
decay of atoms such as Radium-226, Carbon-14, and others.
Radioactive decay = The process where unstable atoms become more
stable by spontaneously ejecting or emitting subatomic particles
or energy rays from the nucleus.
Radium-226 = Ra-226 = A radionuclide of radium, a metallic,
naturally-occurring radioactive element; Ra-226 has an atomic
weight of 226 - each atom has 88 protons and 138 neutrons.
Radionuclide = A radioactive atom specifically identified by the
number of protons and neutrons in its nucleus; e.g., Ra-226 and
Ra-228 are both radionuclides of radium - both have 88 protons in
the nucleus, but Ra-226 has 138 neutrons in its nucleus and Ra-
228 has 140 neutrons in its nucleus. Radionuclides such as
Radium-226, Carbon-14, and Potassium-40, are naturally occurring;
others, such as Plutonium-239 and Cesium-137, are manmade.
Radon-222 = Rn-222 = A radionuclide of radon, a gaseous,
naturally-occurring radioactive element; Rn-222 has an atomic
weight of 222 - each atom has 86 protons and 136 neutrons.
-ix-
-------
Rem = A unit of measurement accounting for the relative
effectiveness of each type of radioactivity to do biological
damage (e.g, gamma rays versus alpha particles). It is estimated
that humans receive an average of 360 millirem (mrem)/yr of
radiation from all sources, including naturally occurring cosmic
rays, radium, and radon, and from medical sources. It is
recommended that human exposure to sources of radiation be as low
as reasonably achievable (ALARA); also, U.S. EPA workers
generally should not exceed a dose of 500 mrem during any 12
consecutive months.
Roentgen = R = A unit of measurement for gamma radiation.
Working level = WL = A unit of measurement for radioactive
elements consisting of any combination of short-lived radon
daughter products in 1 liter of air that will result in the
ultimate emission of 1.3 E+5 million electron volts (MeV) of
potential alpha particle energy. 1.3 E+5 MeV is the approximate
amount of alpha particle energy released from the (Radium-226)
daughter products in equilibrium with 100 pCi of Radium-226.
-x-
-------
DECISION SUMMARY
H&K Sales (Belding Warehouse) Site
Belding, Ionia County, Michigan
A. Site Location and Description
The H&K Sales site is also known as the Belding Warehouse site
(and hereinafter is called "the site") and is located at 100 East
Main Street in the city of Belding, Ionia County, Michigan (see
Figure 1). The Belding Warehouse facility is located on a
several-acre parcel of land in a commercial section of Belding
and is bounded by the Flat River and the C&O Railroad to the
north and east, and by Main and Bridge Streets to the south and
west. Several schools, a hospital, and many residences are
located within a one-mile radius around the site and an estimated
population of 6000 people live within this area.
The Belding Warehouse facility is privately-owned and consists of
two main structures. Typically, each structure is rented out to
diverse business interests for storage or manufacturing space.
The H&K Sales site is that portion of the Belding Warehouse
facility in which World War II (WWII)-era military aircraft
gauges and components had been stored since 1994 . Some of the
aircraft gauges are marked with a luminescent paint containing
Radium-226 (Ra-226), which is a naturally-occurring, but
hazardous, radionuclide. Natural decay of Ra-226 causes radio-
emissions of alpha particles, beta particles, and gamma rays,
which are health hazards, and the formation of Radon-222, which
is also radioactive and a health hazard (see Section C for a more
complete discussion of health hazards due to Ra-226, Rn-222, and
radiation). Investigations have shown that the luminescent paint
is beginning to deteriorate into a powder, creating a concern
that the Ra-226 could leak out of the aircraft gauges into the
environment or create an inhalation risk to anyone who handled
them.
The site building is a single-story structure consisting of three
separate, large rooms, each approximately 9,000 square feet in
area (see Figure 2). Two of the three rooms were packed with
wooden crates containing the WWII surplus material and the third
room was empty. The wooden crates constituted a fire hazard and,
given the building's location in the downtown area, the potential
for a widespread release of Ra-226 into the city (via the smoke
plume) was very great. The site building was constructed with a
concrete floor and foundation, brick and block walls, and a metal
roof. Prior to the removal action described herein, evidence of
cracks in the concrete floor, leaks in the roof, and the presence
of floor drains with an uncertain discharge location pointed
towards the potential for release of Ra-226 into the environment.
No aircraft components were found outside of the site buildings.
-------
Stale Street
Beidmg
Site Location Map
Figure 1
-------
TJIairTSl.
Balding Warehouse Complex
Radium-painted items
Non-Site Buildings
Empty Site Building
fielding Warehouse
Figure 2
-------
-4-.
A portion of the warehouse facility is attached to the site
building; it is a three-story structure that was not used for
storage of any the WWII surplus material. Staff from the
Michigan Department of Environmental Quality's (MDEQ) Drinking
Water and Radiological Protection Division performed a cursory
survey of this building in late 1996 and determined that it had
not been contaminated by the radium-painted materials. It is not
considered to be a part of the site.
B. Site History and Enforcement Activities
1. Site History
The source of the radium-painted aircraf£ components at the site
was a business which originally purchased the items in the late
1940's as military surplus for later resale. The company
(Aircraft Components, Inc.) stored the WWII surplus material in
several Michigan locations including its main warehouse building
located in Benton Harbor. Aircraft Components, Inc. had sold the
radium-painted materials (e.g., to aircraft owners and to WWII
memorabilia collectors) from the Benton Harbor location for
several decades until the owners of the company died in the early
1990's. The main warehouse building was then sold along with the
contents including the aircraft components. The new owners of
the main warehouse building1 then sold some of the WWII surplus
material as scrap to a salvage facility in Arkansas. During one
such delivery to the Arkansas firm, the facility's radiation
alarm was tripped. The facility notified the Arkansas Department
of Health (ADH) and the ADH was able to trace the shipment to
Michigan.
The Michigan Department of Public Health, Division of
Radiological Health (now called the Drinking Water and
Radiological Protection Division of MDEQ) was informed of the
incident and, upon further investigation, determined that the
origin of the material was the main warehouse property in Benton
Harbor. MDEQ staff interviewed the new owners of the Benton
Harbor warehouse and determined that a large portion of their
inventory had been sold to another Michigan firm (H&K Sales,
Inc.) and that the surplus material had been taken by the firm
and moved into the Belding Warehouse facility in early 1994.
MDEQ conducted an investigation of the Belding Warehouse facility
in late September 1994 and estimated that thousands of radium-
painted gauges and other aircraft components were packed in
wooden crates inside part of the facility. MDEQ, using radiation
detection equipment, measured ambient gamma radiation dose rate
lThe Benton Harbor warehouse is also part of a Superfund
site called the "Aircraft Components" site.
-------
-5-.
readings within some of the rooms at over 700 times the naturally
occurring or background level of radiation in Michigan.
Following this discovery, MDEQ requested immediate assistance
from U.S. EPA. In October 1994, U.S. EPA and MDEQ conducted a
radiological survey at the site and confirmed MDEQ's initial
findings. Next, the Agency for Toxic Substances and Disease
Registry (ATSDR), in response to a request for consultation from
U.S. EPA, recorded its observations about the site during a site
visit on May 10, 1995. Following the site visit, ATSDR issued a
health advisory on June 28, 1995. ATSDR advised that the site be
addressed by U.S. EPA without delay, for there was a concern that
a fire at the warehouse could result in the widespread dispersal
of Ra-226 into the environment by the smoke plume and by water
runoff into the adjacent Flat River. Vandalism and theft were
also considered to be potential Ra-226 release mechanisms at the
site.
On July 1, 1995, U.S. EPA Region 5 sent a National Priorities
List (NPL) listing package for the site to Headquarters.
Subsequent to Headquarters' approval of the NPL listing package
on September 22, 1995, U.S. EPA and MDEQ conducted a detailed
site inspection on February 14, 1996, to support an Engineering
Evaluation/Cost Analysis (EE/CA) and a removal action.
The H&K Sales site was placed on the NPL - the Federal Register
(FR) notice- was published on June 17, 1996 (61 FR 30510) and the
effective date of listing was 30 days following FR publication.
2. Enforcement
U.S. EPA had identified several potentially responsible parties
(PRPs) at the time that the removal Action Memorandum for the
site had been signed (July 1996). At that time, U.S. EPA
determined that it was not probable that these PRPs were willing
and able to properly and promptly perform the removal action at
the site. Now that the removal action is complete and no further
Superfund action is necessary, U.S. EPA will evaluate liability
evidence and seek cost recovery to the extent practicable.
C. Summary of Previous Site Status and Risks
Note: This section, based upon the EE/CA, discusses the status of the site
prior to the implementation of the non-time-critical removal action
discussed in Section E, below.
1. Contaminant Identification
Based upon the EE/CA, the compounds of concern at the site were
Ra-226 and Rn-222, both of which had been detected at levels in
excess of health-based action levels (see Table 1) . The source
-------
-6-
of these compounds was the WWII surplus material stored in two of
the three rooms of the site building (described below). The WWII
surplus material included aircraft gauges having dials that had
been marked with a luminous, radium-containing paint. Natural
decay of the Ra-226 isotope contained in the paint causes radio-
emissions of alpha particles, beta particles, and gamma rays and
the formation of Rn-222, which is a radioactive gas and a health
hazard. U.S. EPA estimated that many thousands of radium-
containing gauges and dials were contained in the two rooms of
the site building. Consequently, high ambient gamma radiation
and radon levels were measured within.
Component
Radium-226
Radon
Action Level
20 /iR/hr
4 pCi/L
Levels Measured
f
1000-7000 /zR/hr
33-47 pCi/L
Table 1. Contaminant action levels and measurements
taken at the H&K Sales site, Belding, MI.
Notes: //R = microRoentgens pCi = picoCuriea L = liter
2. Volume Estimates and Concentrations
U.S. EPA's site reconnaissance performed for the EE/CA showed
that "Room 1" contained an estimated 88,000 cubic feet of wooden
crates and pallets containing the WWII aircraft components. A
fuselage from a small aircraft was also stored in the northeast
corner of Room 1.
Gamma dose rate readings in Room 1 ranged from ambient readings
of 0.1 milliRoentgens per hour (mR/hr) near an office area to
7 mR/hr on detector contact with gauges. As a comparison,
background readings average 7-8 microRoentgens per hour (p.R/hr) ,
or 1000 times less than the maximum reading. Most contact dose
rate readings in Room 1 were between 1 and 5 mR/hr, which were
125 to 600 times background levels.
"Room 2" was estimated to contain 80,000 cubic feet of tightly-
packed wooden crates and other containers of radium-painted
aircraft components and gauges.
Ambient gamma dose rate readings in Room 2 averaged 0.5 mR/hr;
readings on contact with individual gauges or some of the crates
ranged from 1 to 5 mR/hr.
"Room 3" was determined to be empty.
-------
-7-.
Radon levels in the warehouse were measured at levels ranging
from 33.4 to 47.4 picoCuries per liter (pCi/L), well above the
U.S. EPA health-based guideline of 4 pCi/L.
3. Human Health Effects
Radiation can pose a health risk since it affects people on a
cellular level. Radiation deposits energy in body tissue, which
can cause cell damage or cell death. In some cases there may be
no effect on a cell, in others the cell may survive but become
abnormal, either temporarily or permanently. An abnormal cell
may become malignant; also, harmful genetic mutations can be
passed on to future generations.
Large doses of radiation can cause extensive cellular damage and
result in death. Smaller doses may not cause death, but the
surviving person or organ may have cell damage, leading to an
increased risk of cancer. The overall extent of damage depends
upon the total amount of energy absorbed, the time period and
dosage rate of exposure, and the particular organ(s) exposed.
Radium-226 is a naturally-occurring radionuclide that can be
found in the environment at low concentrations. Radium can enter
the body by ingestion or inhalation. Exposure to radium at
elevated levels can cause anemia, cataracts, fractured teeth,
cancer, and death. Once ingested, most of the radium exits the
body in the urine and feces over a several-month time period.
Approximately 20% enters the bloodstream and is carried to all
parts of the body, where some of this radium will reside in bone
tissue and be able to cause long-term damage. Dust particles
containing radium can be inhaled into the lungs and lodge there,
where alpha particle radiation can cause great damage to
sensitive lung tissue and cause lung cancer.
Radon is a gas and thus can be inhaled. Radioactive decay of
Ra-226 creates Rn-222 as a daughter product; Rn-222 is also
radioactive. Radon's daughter products, including polonium and
lead, may attach themselves to dust particles and thus can also
be inhaled. Alpha particle radiation from elevated radon levels
and its decay products can cause lung cancer.
4. Exposure Assessment
U.S. EPA examined potential pathways of concern to human health
and the environment under current and future site-use scenarios.
Major pathways of concern for the actual or potential exposure of
nearby human populations, animal, or the food chain to hazardous
substances or pollutants or contaminants include:
-------
a. Current pathways
Inhalation or ingestion of dust containing Ra-226
Both the aircraft gauge seals and the paint containing
Ra-226 are deteriorating as they age, allowing Ra-226 to be
released as dust or on dust particles into the air. Workers
may inhale or ingest the dust particles as they work in the
warehouse buildings. Each time the wooden crates containing
the gauges would be moved, more particulate Ra-226 may be
released to the air.
Long term exposure to radiation from Ra-226
Warehouse workers sorting the aircraft component inventory
and those who purchase the materials may receive adverse
radiation dose levels depending on how close to and how long
they may work with the radium-painted materials. For
example, measurements taken during the EE/CA investigation
revealed gamma radiation levels in the warehouse to be as
high as 7,000 /zR/hr (the background gamma radiation level in
Michigan averages 7 to 10 /LtR/hr) .
Dermal contact with Ra-226
The Ra-226 laden dust may be easily removed from a working
surface, exposing workers to radiation doses via the skin.
Inhalation of radon
Site workers would breathe elevated levels of Rn-222
produced by the radioactive decay of the Ra-226 on dust
particles or in the luminescent paint still on the gauges.
b. Future Pathways
Inhalation or ingestion of airborne dust containing Ra-226
from the site
A fire or an explosion at the warehouse had the potential to
release Ra-226 over a 25-square mile (downwind) area. The
large volume of wooden crates in the warehouse were
flammable and vandalism had occurred in the area in the
past. A fire could have lead to a widespread relocation of
the local population until city-wide radium-cleanup
activities were completed. Fire department personnel
responding to a fire at the site would be at risk of
inhaling or ingesting airborne radium particulates.
Vandals or burglars may be tempted to steal the gauges,
potentially exposing themselves and others to radiation
-------
- 9 -. .
hazards and potentially causing multiple releases to the
environment.
Release to the Environment
In addition to the above events potentially causing a
release to the environment, over the long term Ra-226-laden
dust could migrate outside of the building through cracks in
the floors and walls or via floor drains. Water runoff from
fire-fighting efforts may allow migration of radium to the
nearby Flat River or other off-site locations.
5. Risk Characterization
U.S. EPA performed a streamlined risk assessment for the site
using data collected during the EE/CA investigation. The risk
assessment assumed no corrective action would take place and that
no'Site-use restrictions or institutional controls such as
fencing, groundwater use restrictions, or construction
restrictions would be imposed. The risk assessment determined
actual or potential carcinogenic risks and/or toxic effects the
chemical contaminants at the site would pose under current and
future land-use assumptions. Based upon the results of the risk
assessment, U.S. EPA determined that the levels of Ra-226 at the
site posed an estimated lifetime carcinogenic risk totalling
1.2 x 10"2 under several exposure scenarios. The dominant risk
would be due to ingestion of Ra-226 (comprising 94% of the total
risk value), due to the great harm alpha particle radiation would
cause to internal tissues.
U.S. EPA did not conduct an ecological risk assessment to
characterize the biological resources at the site and adjacent
habitats - since radiation surveys did not measure Ra-226 outside
of the site building, there was no evidence of a release of
Ra-226 into the environment. (If there had been evidence of a
release outside the site building, the adjacent Flat River
environment could have been impacted and it would have been
investigated for possible contamination.) Lastly, since the
operational practice was to merely store the aircraft components
in the warehouse and since U.S. EPA was able to react quickly to
the threat of release, neither surface water nor groundwater
resources were considered to be impacted.
D. HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Responsiveness Summary (Section VI) discusses the involvement
of the community during the EE/CA and the removal process and
shows that the public participation requirements of CERCLA
Sections 113 (k) (2) (B) (i-v) and 117 have been met at the site.
The decision denoted herein is based on the Administrative
Record.
-------
U.S. EPA completed the EE/CA in April 1996. The EE/CA evaluated
two options for addressing the Ra-226 hazards at the site. On
April 15, 1996, U.S. EPA issued a Proposed Plan for addressing
the need to mitigate any risk to the Belding community. The
public comment period began on this date and ended on May 15,
1996. U.S. EPA held a public meeting in the community on April
25, 1996 to discuss the results of the EE/CA and the provisions
of the Proposed Plan and to accept public comments.
Following the conclusion of the comment period, U.S. EPA signed a
removal Action Memorandum on July 16, 1996, detailing the non-
time-critical (NTC) removal action it would undertake at the
site. U.S. EPA's responses to comments received during the
public comment period can be found in the Action Memorandum.
The NTC removal action was begun on January 6, 1997.
Periodically, at the request of the Belding City Manager, U.S.
EPA updated the city council on the progress of the cleanup
action. Nearing the completion of the removal action, on
September 11, 1997, U.S. EPA issued the Proposed Plan for this
decision document, and held a public meeting on September 16,
1997, at which to accept comments on the preferred final remedy.
Throughout the NTC removal action, the community has been kept
informed and has remained very supportive of U.S. EPA's cleanup
activities at the site (see Responsiveness Summary).
E. Scope and Role of Early Response Action
In January 1997, U.S. EPA initiated an early response action at
the site. The early action at the site was considered to be
nationally significant or precedent-setting because it involved a
response action to be taken wholly within a building or
structure. U.S. EPA determined that its early response action
was appropriate due to the potential for Ra-226 to be rapidly
dispersed over a wide area should a fire or explosion occur at
the warehouse. This would have created an imminent and
substantial endangerment to public health, or welfare, or the
environment. Also, U.S. EPA determined that no other authority
was able to respond to the potential health threats in a timely
fashion. Accordingly, the agency undertook the early response
action pursuant to OSWER Directive 9369.3-12, Response Actions at
Sites with Contamination Inside Buildings.
U.S. EPA began the planning stage of the cleanup in September
1996. At that time, U.S. EPA contracted with another federal
agency, the U.S. Department of the Interior's Bureau of
Reclamation (USER), to manage the cleanup on-site. The on-site
cleanup work began in January 1997 and included the following
activities:
-------
-117
The building was secured to prevent release of radiation to
the environment during the handling of the radium-painted
materials and to prevent entrance to the clean-up areas by
untrained persons;
A detailed, base-line radiation survey using radiation-
detection devices was performed in the buildings: 1) to
determine where "hot-spots" existed to alert site clean-up
workers and prevent exposure to high doses of radiation
during the cleanup and 2) to more accurately predict where
radium-painted items were stored (before the large number of
storage crates were opened for materials sorting)/
Radium-painted materials were segregated and packed into 55-
gallon drums for shipment to the U.S. Ecology low-level
radioactive waste disposal facility in Richland, Washington.
Two shipments, each containing an average of 85 containers
of radium-painted materials, were sent off-site for
disposal. Each container held between 200 and 300 radium-
painted components, which means that more than 34,000
radium-painted aircraft components were transported off-site
for disposal. U.S. Ecology's disposal criteria mandated
that each shipment average less than 10 nanoCuries (nCi) of
Ra-226 per gram of material;
A waste shredder was set up in the building to process
packaging materials and other non-hazardous items for
disposal in a local municipal landfill. These materials
were tested to ensure that they did not exceed Region 5's
criterion for disposal of radioactive items in municipal
landfills (5 pCi/gram). The Region 5 criterion is ten times
lower than the state criterion (at 50 pCi/g), which means
that the state criterion was followed as well. U.S. EPA
sent 56 loads of material to the local landfill; each load
contained about 540 cubic feet (averaging about 4.5 tons) of
shredded wastes, for a total of 30,240 cubic feet (252
tons). Using the local landfill was a safe and less-costly
alternative to sending the non-hazardous wastes to a
disposal facility in Utah (see next entry);
Approximately 1,000 cubic feet of material was packaged and
shipped to Envirocare, Inc., a low-level radioactive waste
disposal facility in Utah. This material was not painted
with Ra-226, but had enough Ra-226-dust in it to exceed the
federal criterion for disposal in the local landfill. The
shipment did not exceed 2 nCi/g, the criterion for disposal
at the Envirocare facility;
More than 4,500 cubic feet of aircraft components and other
materials were subjected to radiation surveys, cleaned if
necessary, and then released back to the original owners
(H&K Sales, Inc.) for unrestricted use, including resale to
-------
-12-
collectors, etc. Items such as airplane propellers, nuts
and bolts, and certain pieces of heavy machinery were
reclaimed by the owners, saving the U.S. EPA substantial
sums in disposal costs; and
Smaller amounts of other hazardous items, including radium-
painted components containing such materials as mercury and
diesel fuel, were properly packaged and shipped off-site for
disposal. The mercury-containing components, for example,
were shipped to a processing facility in Texas where the
mercury will be reclaimed for re-use and then the radium-
painted components will be shipped-to the U.S. Ecology
disposal facility in Richland, Washington.
Lastly, U.S. EPA performed a preliminary-final radiation
survey of the affected buildings to' confirm whether the
cleanup had been completed. Using data from the baseline
radiation survey, those portions of the building floors and
walls that contained levels of Ra-226 above standards (see
Table 2, next section) were cleaned before the buildings
were released back to the owner for unrestricted use.
F. Summary of Current Site Status
Both U.S. EPA and MDEQ performed final radiation surveys after
the building floor and wall cleanup was completed. Data from the
final radiation surveys showed that the site was cleaned up to
meet the standards for Ra-226 generally used by the U.S. Nuclear
Regulatory Commission (NRC) and the Drinking Water and
Radiological Protection Division of MDEQ to allow for the
"unrestricted release" of property. Unrestricted release is the
term applied to the future uses of any items of property, without
regard to restrictions, so that the public will not be exposed to
unacceptable levels of radiation and/or radioactive materials.
Table 2 (below, next page) gives the minimum standards to be met
for unrestricted release and are "Acceptable Surface
Contamination Levels" based on NRC guidelines.
U.S. EPA has determined that no further remedial action needs to
take place at the site for the following reasons-.
The site no longer contains Ra-226 above standards (Table 2)
or above naturally-occurring levels.
The warehouse buildings have been emptied of the radium-
painted materials, thus the risk of release of Ra-226 to the
environment (air, ground water, surface water, or soil) by
fire or other means has ended.
-------
-13-
Average Level, Total Surface
(Fixed and Removable)
Maximum Level, Surface
(Fixed and Removable)
Removable Amount, Surface
100 dpm (alpha radiation) per
100 cm2 surface area
300 dpm (alpha) per 100 cm2
20 dpm (alpha) per 100 cm2
Table 2: Acceptable Surface Contamination Levels for Radium-226
Notes: 1. dpm = disintegrations per minute 2. The Average Level is to be based
on readings taken on less than 1 meter2 (10,000 crcf) surface areas. 3. The
Maximum Level cannot be taken from an area that exceeds 100 cm2. 4. The
Removable Amount of radiation levels refers to Ra-226 particles that are not
fixed to a surface but that can be removed from the surface by wiping the surface
with a soft absorbent paper, thereby transferring the Ra-226 to the paper.
5. The source of these standards is the U.S. Atomic Energy Commission (now the
NRC) Regulatory Guide 1.86: Termination of Operating Licenses for Nuclear
Reactors, June 1974.
There are several floor drains in Rooms 1 and 2; however,
these drains had been plugged prior to the placement of the
radium-painted materials at the site (for other reasons) and
thus were not a potential conduit for Ra-226 to be released
to the environment. During the final radiation survey, the
drains were found to not have Ra-226-contamination in them.
Radiation survey data from certain areas outside of the site
building (e.g., "traffic" areas) ensured that no radium was
tracked off-site by site cleanup workers and that no radium
had been released to the environment in the short time that
the materials had been stored at the warehouse.
Radon gas levels have fallen to below 4 pCi/L inside the
buildings.
Hence, the increased risks to human health and the environment
posed by the site have been removed.
G. Applicable or Relevant and Appropriate Requirements (ARARs)
On August 26, 1997, U.S. EPA issued Superfund Radiation Guidance
(OSWER Directive 9200.4-18) to address the cleanup of NPL sites
contaminated with radionuclides. The guidance establishes
methods for determining protective cleanup levels for
radionuclides at NPL sites and discusses the role of radiation-
related ARARs at such sites. The guidance established a minimum
recommended cleanup level of radionuclides at a site such that
the residuals offer a radiation dosage of less than 15 mrem per
year, for an estimated risk of 3 E-4. Once the standards listed
in Table 2 were met, U.S. EPA achieved the Superfund Radiation
-------
-14r
Guidance risk goal at the site: the values listed in Table 2 are
very nearly background levels, which means that the residual risk
is less than 3 E-4.
Other site cleanup ARARs can be broken down into five functional
categories:
Release criteria for objects contaminated with Ra-226
Radon criterion
Gamma criterion
Bulk waste landfill disposal criterion
Dust, debris or recyclable material criterion
Soil cleanup criteria are not considered to be ARARs at the site
since no soil contamination is present.
t
Release Criteria for Objects
Federal and state guidelines are discussed in Section F., above.
Radon Criteria
U.S. EPA recommends that radon exposure averages 4 picoCuries per
liter (pCi/L) on an annual basis as a remedial action criterion.
This value is derived from a unit of measurement of Radon-222's
decay products, termed working levels (WL): the decay products
produced by radon carry the majority of the radiation dose,
predominantly in the form of alpha particles.
40 CFR 192 sets out an objective of an annual average of 0.02 WL
and an upper limit to no more than 0.03 WL. In the somewhat
aerated environment of many homes and buildings, 200 pCi/L of
radon corresponds to 1 WL of decay products. U.S. EPA Region 5
uses 0.02 WL as a radon cleanup criterion, which corresponds to
4 pCi/L.
As found in the state's Ionizing Radiation Rules, Part R325.5267,
App. A7, MDEQ's Drinking Water and Radiological Protection
Division ascribes to a radon limit of 3 pCi/L (0.015 WL) above
naturally occurring background that a registrant may release from
its facility.
Gamma Criteria
40 CFR 192. 12 (b) (2) sets a standard of 20 /zR/hr (Table 1) over
background radiation levels for gamma radiation in buildings.
In its "Cleanup and Disposal Guidelines for Sites Contaminated
with Radium-226," MDEQ's Drinking Water and Radiological
Protection Division has designated 10 /aR/hr over background,
measured 1 meter off the surface, as its gamma radiation
criterion.
-------
-15r
Bulk Waste Landfill Disposal Criterion
U.S. EPA Region 5's policy for disposal of Ra-226 materials in
municipal type landfills is the Ra-226 concentration should not
exceed 5 pCi/g above background.
Michigan permits Ra-226 of sufficiently low concentrations to be
disposed of in designated landfills. As stated in MDEQ's
"Cleanup and Disposal Guidelines for Sites Contaminated with
Radium-226,"
For disposal of Radium-226 contaminated materials in the
form of bulk waste, such as contaminated soil or
contaminated debris, materials containing a Radium-226
concentration not exceeding 50 pCi/g, averaged over any
single shipment, can be accepted in a Type II solid waste
landfill, as defined in Act 641, Public Acts of 1978, as
amended, and permitted by the Michigan Department of
Environmental Quality. The maximum Radium-226 concentration
within any single shipment as determined by representative
sampling must not exceed 100 pCi/g.
MDEQ treats the above 50 pCi/g and 100 pCi/g levels as including
background levels.
Dust. Debris or Recyclable Material Criterion
U.S. EPA has no criterion for this material.
In its "Cleanup and Disposal Guidelines for Sites Contaminated
with Ra-226," MDEQ's criterion is listed as 5 pCi/g above natural
background in any volumetrically defined material.
The NTC removal action at the site was performed and completed in
accordance with the above-listed ARARs.
H. Site Returned to Owner
The Belding Warehouse facility was returned to the owner for
unrestricted use upon U.S. EPA's complete demobilization from the
site on October 17, 1997. Subsequently, the site is now eligible
for deletion from the NPL.
-------
RESPONSIVENESS SUMMARY
H&K Sales (Belding Warehouse) Site
Belding, Ionia County, Michigan
The public participation requirements of CERCLA §113(k)(2)(B)(i-v)
and CERCLA §117 have been met during the remedy selection process
for the H&K Sales (Belding Warehouse) site (the site). Section
113(k)(2)(B)(iv) and 117(b) of CERCLA requires U.S. EPA to
respond "...to each of the significant comments, criticisms, and
new data submitted in written or oral presentations" on a
proposed plan for a remedial action. This Responsiveness Summary
addresses those concerns expressed by the public, potentially
responsible parties (PRPs), and governmental bodies in written
and oral comments received by U.S. EPA regarding the proposed No
Action remedy for the site.
Background
U.S. EPA issued a fact sheet/proposed plan in April 1996 to the
public in Belding, Michigan, prior to the start of the non-time-
critical removal action. The Agency also hosted a public meeting
on April 25, 1996, to provide background information on the site,
explain the Superfund process, provide details of the proposed
removal action, and solicit public comment regarding the proposed
cleanup action. Following receipt of public comment, U.S. EPA
signed a removal Action Memorandum on July 16, 1996. U.S. EPA
then began the removal action on January 6, 1997, and completed
it on October 17, 1997.
On September 11, 1997, U.S. EPA issued a second fact
sheet/proposed plan to the public to summarize the results of the
removal action and to present its recommendation that, upon the
pending completion of the removal action, no further remedial
action take place at the site. U.S. EPA held a second public
meeting on September 16, 1997, to discuss the results of the
removal action in greater detail, to answer any questions
regarding the cleanup action, and to take oral comments regarding
the No Action proposal. Information repositories have been
established at the two following locations: U.S. EPA Region 5,
77 W. Jackson Blvd., Chicago, IL 60604 and the Alvah N. Belding
Library, 302 E. Main Street, Belding, Michigan 48809. The
Administrative Record has been made available to the public at
the these locations as well.
U.S. EPA answered questions about the site and the No Action
alternative under consideration. Formal oral comments on the
Proposed Plan were documented by a court reporter. A verbatim
transcript of this public meeting has been placed in the
information repositories and in the Administrative Record.
Written comments were also accepted at this meeting. The meeting
was attended by approximately 60 persons, including local
residents.
-------
-17--
The proposed plan was available for public comment from September
11, 1997 through October 10, 1997. U.S. EPA placed
advertisements announcing the availability of the proposed plan
and the start of the comment period in the Greenville Daily News.
During the comment period, U.S. EPA received one written
submittal of comments and two oral comments concerning the
proposed plan. Comments received during the public comment
period and the U.S. EPA's responses to those comments are
included in this Responsiveness Summary, which is a part of the
Record of Decision.
Summary of Significant Comments
A. Writ-ten
Comment 1: Howard A. Scheid, Belding, MI:
"The above [scheduled return of the building back to the
owner] bothers me. What is to stop someone from doing the
same thing in the future?"
Response 1:
Upon the conclusion of the cleanup action, the building will
have been checked by U.S. EPA and state staff to ensure that
it does'not contain radium above the standards cited in the
Decision Summary. Therefore, return of the building back to
the owner's control is allowable and safe from a
radiological point of view. From that point on, it will be
the owner's responsibility to ensure that he does not accept
unauthorized radioactive items into the building for storage
or other future uses. Also, people in the State of Michigan
may contact representatives of the Drinking Water and
Radiological Protection Division of the Michigan Department
of Environmental Quality ((517) 335-8204) for assistance
with similar radiological matters.
B. Oral
Comment 2: Mary Keena, Belding, MI:
"I just want to thank you people because -- to be the first
in Michigan to have a site cleaned up. We really owe you
one. Thanks.... you certainly resolved it."
Comment 3: Darwin Feuerstein, Belding, MI:
"As a representative of the city council of Belding, I would
like to thank the people involved in the actual cleanup of
the site. I know that it was a monumental task and it was a
very special consideration on the part of the council to
-------
-1ST
find an answer, a solution to the problem over there. And
the speed at which that was identified as a site and action
was taken to clean it up surprised the council and a lot of
people within the town, and once again, I'd just like to
thank everybody involved in that. Thanks."
Responses 2 and 3:
U.S. EPA and its representatives appreciate the support in
this matter.
------- |