The United Community Hospital was originally opened in southwest Detroit as Southwest Detroit Hospital in 1974. The hospital was operated by various owners under various names until 2006, when it was liquidated by the State of Michigan. The building has remained closed and unoccupied since 2006. The City of Detroit requested EPA assistance with this site in June 2012.
EPA conducted a site assessment on June 21, 2012, and returned to the site on August 8, 2012 to collect additional information. During the site visits, EPA observed:
• Six mercury spills visible on the floor in former patient rooms which appeared to be from broken blood pressure cuffs;
• Medical waste including syringes, sharps containers and vials of dried blood on the first and third floors of the building; and
• Bottles of liquid medications including Heparin, Ketorolac, and Levaquin on the 3rd floor near the nurse’s station.
Ambient levels of mercury at the site of up to 50,000 nanograms/cubic meter were later measured at the site.
The site was in disrepair, with evidence of trespassing including broken windows, paintballs and graffiti; and evidence of scrapping activity including removal of power cords from machines and of lead from walls of x-ray rooms. The building is locked, and windows have been boarded up, however, trespassers continue to gain access to the building. The site grounds are unfenced, allowing access by the public.
Mercury is a characteristically hazardous waste under the Resource Conservation and Recovery Act (RCRA), 42 U.S.C. 6901 et seq., as amended, and 40 CFR 261.24. Mercury exhibits the characteristic of toxicity (D009), and is therefore a hazardous substance under Section 101 (14) of CERCLA, 42 U.S.C. 9601(14).
Medical waste is not a listed or characteristically hazardous substance, however is considered to be a pollutant or contaminant under Section 101 (33) of CERCLA, 42 U.S.C. 9601(14). Pollutant or contaminant is defined as “any substance…including disease-causing agents, which after release into the environment and upon exposure, ingestion, inhalation, or assimilation into any organism…will or may reasonably be anticipated to cause death, disease, behavioral abnormalities, cancer, genetic mutation, physiological malfunctions…” The biological waste at the site was not organized, secured, or maintained in a manner necessary to prevent exposure and/or release. Medical waste transport and disposal is heavily regulated by a number of governmental agencies due to its potentially infectious nature.
Given the site conditions, the nature of the known and suspected hazardous substances, pollutants and contaminants on site, and the potential exposure pathways, actual or threatened releases of hazardous substances from this site, if not addressed by implementing the response actions selected in the Action Memorandum, may present an imminent and substantial endangerment to public health, welfare, or the environment. Therefore, a time critical removal action was initiated at this site on July 15, 2013. This removal action will directly address actual or potential releases of hazardous substances at the site, which may pose an imminent and substantial endangerment to public health, or welfare, or the environment.
