Des:

}gnation—Summary -—
Former Dow Chemical Company

INTRODUCTION

The Department of Energy (DOE), Office of Environmental Restoration, has
reviewed the past activities of the Atomic Energy Commission (AEC) at the
Former Dow Chemical Company in Madison, Illinois, and has completed a
radiological survey of the site (Cottrell and Williams, 1990). DOE has
determined that residual uranium dust levels in overhead beam locations exceed
current DOE radiological guidelines (USDOE, 1987; 1990) for use of the
building without radiological restrictions. Because of the inaccessibility
and limited extent of the residual contamination, there is no significant risk
to workers or the general public under current site use.

From the results of the survey and a review of available historical documents,
the DOE has concluded that this site shal] be designated for remedial action
under the Formerly Utilized Sites Remedial Action Program (FUSRAP) and
assigned a low priority. The remainder of this report summarizes the site
information and the designation decision.

BACKGROUND
Site Function (Williams, 1991)

The Dow Chemical Company. offices and facilities in the St. Louis area supplied
materials (chemicals, induction heating equipment, and magnesium metal
products) and services under purchase orders issued by Mallinckrodt Chemical
Works, a prime AEC contractor. In 1957, Mallinckrodt subcontracted to Dow to
conduct "...certain research and development work in gamma phase extrusion of
uranium metal, ...to be done at Dow’s Madison, Illinois plant; ...."

According to the subcontract, the work was to be performed in monthly work
cycles of 28 hours each for 12 consecutive months. The makeup of each work
cycle was defined as 6 hours for set-up time, 16 hours for experimentation
(extrusion), and 6 hours devoted to cleanup.

in addition to auxiliary equipment and tool design, Dow supplied the use of
its press, Tabor, and plant facilities necessary to perform the work cycles.
Mallinckrodt responsibilities included: procurement and installation of the
auxiliary equipment designed by Dow; modifications to the dust arresting and
other protective equipment required by plant area surveys made from time to
time during the course of the work; arrangement for complete survey of
breathing zone air quality to be conducted periodically by the AEC Health and
Safety Laboratory; establishment of a program for area clearance after each
cycle; supply (to Dow) of the uranium bijlets allocated for each work cycle;
and pick up of the billets or extruded metal at the end of a work cycle.



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OAK RIDGE
NATIONAL
_ LABORATORY

MARTIN MARIETTA

OPERATED BY

~ “ORNL/TM-1T5?

PRELIMINARY RESULTS OF THE
RADIOLOGICAL SURVEY
AT THE FORMER
DOW CHEMICAL COMPANY SITE,
MADISON, ILLINOIS ...

W. D. Cottrell
J. K. Williams

~ MARTIN’ MARIETTA ENERGY SYSTEMS, INC.
FOR THE UNITED STATES
DEPARTMENT OF ENERGY



_-Designation Summary.
Former Dow Chemical C

Authority Review (Williams 1991)

In 1991, the DOE determined that it has the authority to conduct remedial
action at the site (USDOE 1986, Williams 1991). This determination of
authority under FUSRAP was based in part upon the following significant
factors.

Available records indicate that Dow was directly supervised by the Atomic
Energy Commission (AEC) prime contractor. AEC staff approved the
arrangements to use the facility and provided indemnification of Dow
against atomic hazards. .

As a part of the operations at the site, there were requirements
concerning security, accountability, health, and safety. These were
controlled by AEC directly or through its prime contractor. The AEC was
expected to periodically monitor air quality during operations. The
contamination at the site most likely resulted from airborne deposition
of uranium on the roof support beams. .

The uranium machined at the site was owned by the government.

AEC staff were substantially involved in the subcontract negotiation; as
a result, AEC approved the indemnification clause. Mallinckrodt was also
indemnified by the AEC; thus, AEC indemnified Dow against atomic hazards
either directly by approving the subcontract or indirectly through the
indemnification of Mallinckrodt.

DESIGNATION DETERMINATION

Survey results indicate that there is residual radioactive contamination on
overhead beams at the site. The DOE has authority to conduct remedial action
at the site under FUSRAP. Consequently, the site is hereby designated for
inclusion in FUSRAP.

On the basis of the ranking procedure of the FUSRAP protocol (USDOE, 1986),
the site is classified as a low priority site. This classification is based
on the inaccessibility and limited extent of the residual contamination.
Under current use conditions, there is no significant risk of exposure to site
workers or the general public.



— Designation Summary.

Former Dow Chemical Company

In March 1960 the Uranium Division of the Mallinckrodt Chemical Works issued a
purchase order for the straightening of Mallinckrodt-supplied uranium rods.
Delivery of the rods to the Dow plant and pickup after the straightening
operation was performed by Mallinckrodt personnel. Two rod straightening
campaigns were identified in the purchase order. One was comp] eted in
December 1959. The other was completed in January 1960. Cleanup of the area
after each campaign was identified and costed as a separate and distinct item
in the purchase order. The actual periods of performance and the quantities
of uranium metal involved in these operations is unknown. However, the total
value of the purchase order and the unit cost identified with lot size
indicate that the quantity of metal involved was probably small.

No other operation or period of involvement with the processing or handling of
radioactive materials at the former Dow Madison plant have been discovered.

Site Description (Cottrell and Williams, 1990)

Madison, Illinois is Tocated northeast of St. Louis, Missouri, across the
Mississippi River. The former Dow Chemical Company Plant is in West Madison
at the intersection of College and Weaver Streets. The plant consists of a
large, multisectional complex of ten interconnecting buildings with a total
area under roof of approximately 1.4 million square feet. The area in which
the uranium extrusion and rod-straightening work occurred is located in
Building 6, a large multistory metal building with concrete floors. The
building is used by the current owner, Spectrulite Consortium, for metal
extrusion and storage of equipment and parts. -

Owner History

The Dow Chemical Company owned the site until 1969. The current owner and
operator of the plant is the Spectrulite Consortium, Incorporated.

Radiological History and Status (Cottrell and Williams, 1990)

Mallinckrodt may have conducted cleanup of the plant facilities after uranium
processing operations; however, no records -have been located that provide
details of the plant cleanup. Consequently, a radiological survey was
conducted by Oak Ridge National Laboratory in March, 1989. Survey results
indicate the presence of elevated concentrations of Uranium-238 and Thorium-
232 in dust sampled from overhead beams in the building where the uranium
extrusion and rod straightening work was conducted. The maximum uranium
surface contamination in dust was 13.6 times the average DOE guideline, while
average uranium contamination from 18 samples was 2.5 times the DOE guideline

(USDOE 1987, 1990).



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ORNEFEM-1155;

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OAK RIDGE
NATIONAL
LABORATORY

PRELIMINARY RESULTS OF THE

RADIOLOGICAL SURVEY
‘AT THE FORMER
DOW CHEMICAL COMPANY SITE,
MADISON, ILLINOIS ..

W. D. Cottrell
J. K. Williams

OPERATED BY

MARTIN HARIEFTA ENERE YSTEMS EN a
FOR THE UNITED STATES
OEPARTMENT OF ENERGY



DOE F 1525.8
(6-89)
EFG (07-50)

United States Government

Crtegay #3

DATE:
REPLY TO
ATIN OF:

SUBJECT:

TO:

SEP 25 i992
EM-421 (W. A. Williams, 903-8149)

Authorization for Remedial Action at the Former Dow Chemical Company
Facility in Madison, Iilinois .

L. Price, OR

The site of the Former Dow Chemical Company in Madison, Illinois, which is
currently owned and operated by the Spectrulite Consortium, is designated
for inclusion in the Formerly Utilized Sites Remedial Action Program
(FUSRAP). This designation is based upon the results of a preliminary
radiological survey and other information described in the attached
Designation Summary. The authority determination and preliminary survey
report also are attached for information.

The site has been assigned a low priority under the FUSRAP protocol, as
the contamination is localized to overhead beams and limited in extent.
Under present building use, it is highly unlikely that an individual
working in or frequenting these remote areas would receive a significant
exposure. Because the contamination is limited in extent and contained
entirely inside the building, we recommend that cleanup of the site follow
the proposed expedited protocol currently under development. We will work
closely with your staff, the designation contractor, and the property
owner to ensure that remedial action is conducted efficiently.

The effect of this designation on the FUSRAP baseline should be evaluated,
documented and submitted for approval under the baseline change control

procedures.
Aehege Zz

James W. Wagoner II

Director

Division of Off-Site Programs
Office of Eastern Area Programs
Office of Environmental Restoration

Attachments

memorandum ——— >



esignation. Summar, Summary
Former Dow Chemical Company

REFERENCES

Cottrell, W.D. and J.K. Williams, 1990: Results of the Radiological Survey at
the Former Dow Chemical Company Site, Madison, Illinois. ORNL/TM-11182. Oak
Ridge National Laboratory, Oak Ridge, Tennessee, December.

United States Department of Energy (USDOE), 1986: Formerly Utilized Sites
Remedial Action Program. Summar: Identification - Characterization -
Designation - Remedia} Action ~ cenebpeel ite Office. of Nuclear Energy,

January.

USDOE, 1987: U.S. Department of Eneray Guidelines for Residual Radioactive
Materials at Formerly Utilized Sites Remedial Action Program and Remote

Surplus Facilities Management Program Sites. Revision 2, Office of Nuclear

Energy, March.

USDOE, 1990: Radiation Protection of the Public and the Environment. DOE
Order 5400.5. Office of Environment, Safety, and Health, February 8.

.Williams, W.A., 1991: “Authority Determination -- Former Dow Chemical Company
Site, Madison, IL." DOE correspondence from Office of Environmental
Restoration to file, February 21.



INTRODUCTION. 2 2 ee ee ee ee tt
BACKGROUND
Site Function. 2... -- ee ee ee Se ee
Site Description .--. ee ee eee eee ete ee
Owner History . 2 2 6. ee ee ee et ee
Radiological History and Status... .-- +--+ +++
Authority Review .--- +--+ 2 e+ eee ee ee
DESIGNATION DETERMINATION - . . - 2 +--+ ee ee eee eee

REFERENCES 2 0 2 62 ee ee ee ee ee re

PS F WWNNH



FORMERLY UTILIZED SITES
REMEDIAL ACTION PROGRAM

DESIGNATION SUMMARY
FOR THE FORMER
DOW CHEMICAL COMPANY
IN MADISON, ILLINOIS

September 1991

U.S. Department of Energy
Office of Environmental Restoration



Distribution:
EM-40 (2)
EM-42 (3)

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M. White Review:

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