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Strube Incorporated (Commonwealth of Pennsylvania)

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1.0 Site Identification

Type of Site: Complex Materials
Location: Lancaster Co., PA
License No.: PA-1004
Docket No.:  
License Status: Decon

2.0 Site Status Summary

The Strube, Inc. founder began in 1957 to purchase surplus military aircraft parts at government auctions for eventual resale. The parts included an undetermined number of gauges, instruments and parts containing radium luminous paint. The parts were stored in eight warehouses at seven different location scattered about western Lancaster County, PA. Many of the warehouses were in poor structural condition and only one had an active fire suppression system.

In 2007 the Department became aware that Strube, Inc. possessed licensable quantities of radium and immediately began working toward bringing them under a license. Strube, Inc. expressed their desire to begin decommissioning the warehouses and, as a result, was issued a decommissioning license in August, 2007. During the licensing process Strube, Inc. provided an initial estimate stating that there were approximately 70,000 radioactive parts intermingled throughout an estimated inventory of millions of other aircraft parts. The Department's inspection of the warehouses revealed that the actual quantity of affected parts were many times larger.

The licensee committed to an aggressive but reasonable timeline for completing the cleanup of the facilities. The Department performed an initial inspection in October 2007 and noted multiple violations of PA Radiological Health regulations. The Department found that the licensee had made almost no progress toward the decommissioning, including not making any shipments of radioactive waste. Because of the violations and the discovery that hazardous and flammable materials were being stored along with radium containing parts in some of the warehouses (most without fire suppression systems), the Department determined that these warehouses posed an imminent threat to the health and safety of the surrounding communities (especially in the case of a fire) and requested the assistance of the EPA's Emergency Removal Program.

EPA responded and, using a contractor, performed an emergency removal action that resulted in the segregation, packaging and shipment for disposal of more than 400,000 radium containing instruments, gauges and parts from 6 of the 8 warehouses. The Department then performed follow-up radiation surveys to verify removal of the bulk of the contaminated parts. Based on the EPA removal action these sites were no longer considered to pose an imminent radiological threat.

The licensee (under EPA order) employed a contractor to remove contaminated parts and soil from one site that consisted of 2 warehouses. The contractor completed the removal and performed a final status survey. Based on the licensee's removal of all radioactive items from this site the Department determined that this site no longer posed a radiological threat. In addition, the Department confirmed the final status survey, removed the site from the license, and released it for unrestricted use.

After EPA completed its emergency removal action in 6 warehouses, areas of fixed contamination and possibly a small number of contaminated parts remained. The licensee then faced the task of characterizing the warehouses and then removing any contamination and/or radioactive items. Upon completion of remediation and final survey by the licensee, each building requires confirmatory measurements by PADEP before release for unrestricted use is granted.

PADEP approved a decommissioning cost estimate in the fall of 2009 for the remaining buildings for over $800,000. Strube remediated and requested unrestricted release of one property in late 2009. PADEP was able to confirm the condition of the property and removed it from the license.

Most of 2010 was spent trying to establish a financial assurance mechanism that would allow Strube to stay in business, while providing PADEP with some assurance that the cleanup of the remaining properties could be accomplished. The mechanism chosen involved the use of an escrow account that required Strube to make minimum payments throughout the calendar year along with depositing the proceeds from the sale of any released properties. PADEP had previously pulled $281,000 from Strube's financial assurance in 2008. PADEP transferred that amount into the escrow account. PADEP retained signature authority over any money that Strube wished to spend out of the account.

During 2010, Strube's contractor completed remediation of a large warehouse in Columbia, PA and in January, 2011, after confirmatory measurements by PADEP, that warehouse was released from the license. Between early-2011 and spring-2013, Strube's contractor completed remediation of 3 additional warehouses. In each case the warehouses were checked by PADEP and subsequently released from Strube's license.

Low-level radioactive waste generated during the remediation of Strube warehouses during 2010 through 2013 was consolidated, packaged and transported to the one warehouse that remains on the Strube license. That waste will be addressed along with any waste generated during the remediation of that last warehouse.

3.0 Major Technical or Regulatory Issues

The Licensee initially attempted to perform the decommissioning work without the assistance of an experienced contractor. The results were multiple license violations and a failure to comply with the decommissioning timeline required in the license. The discovery of hazardous materials in the buildings added greatly to the Department's level of concern. Concerns also grew as it became apparent that the quantity of radioactive parts was significantly underestimated.

The licensee was unable to post a complete financial assurance mechanism up front. PADEP has worked with them on an agreement to make regular payments into an escrow account to build up funding for future cleanup. This mechanism, along with funds resulting from a settlement from the U.S. Dept. of Defense, enabled Strube to complete the cleanup of all but one warehouse. The cleanup of the remaining warehouse and disposal of the waste presently stored in that warehouse must await the sale of one or more of the remediated properties or the accumulation of sufficient funds through Strube's contributions to the escrow account.

Page Last Reviewed/Updated Monday, November 25, 2013