YAN 26 1964 .

Mr. Edgar 0. Batley, Director
Division of Licensing, Registration 1
and Standards

Bureau of Radfation Control vos
Texas Departinent of Health
1100 West 49th Street icjal
Austin, Texas 78756

Mille
Dear Mr. Batley:

1/23/.
1 am replying to your letter of December 6, 1983, relative to maintaining
the Pasadena Chemice) Company, Pasadena, Texas, in the Formerly Utilized
Sites Remedial Action Program (FUSRAP). Dr. Mott's letters of March 27,
19@1, and August 1}, 1981, stated that, although the site was “designated”
for remedial action on Harch 19, 1981 (that is, it should be considered for
remedial action), the Department of Energy's (DOE) Office of General Counsel
concluded from review of available records that there is insufficient docu-
mentation to provide us the necessary authority to conduct remedial action
at the site. Therefore, DOE has no plans to conduct remedial action at the
Pasadena Chemical Company site.

The reports that you mentioned in your letter were based on out-of-date
information, and included some sites, such as the Pasadena Chemical Company,
where DOE cannot establish authority based on documentation, but which were
included in a draft Jegislative proposal for congressional authorization
prepered by DOE. This draft legislation 4s no loncer being proposed for
submittal to Congress, Therefore, we sugoest that the State of Texas,
Department of Health, should take the appropriate action to remove the
radioactive contamination from this sfte. It appears that removal and
disposal of the contaminated sink and drains as low-Jevel radioactive waste

would be the appropriate course of action to take to rectify the situation.

The BOE will provide technical advice to the State on the cleanup, {f you
wish. Please call Mr, Arthur J. Whitman of my staff (301-353-5435) if there
are any technical questions, or contact ltr, Steven Miller (202-252-6947) of
the Office of General Counsel, regarding the question of authority.

bee: Sincerely, ated

S. Miller, GC-34 *Comments included NE-24; Anne an: 2s 353-5439:1/24/84 :AW39:
E. Keller, GR Crigins2 simed ty | 3.43.1

A. Whitman, NE-24 J. E.
Aerospace John £, Baublitz, Director

: Division of Remedial Action Projects
NE-73 (4) Office of Terminal Veste Disposal
NE-24 RF and Remed{al Action
Whitman RF Office of Ruclear Eneray



TK.) Sere

MAR 27 1981

Br. L. D, Hinson

Plant Manager

Pasadena Chemical Corporation
P. 0. Box 3447

Pasadena, Texas 77501

Dear Mr. Hinson:

T acknowledge receipt of your letter of May 21, 1980, and your intention to
treat the pilot plant's sink and drain es contaminated material, Based on the
radiological survey conducted at the facility uncer the Formerly Utilized Sites
Renedial Action Program, the Departaent of Eneray has determined thet vour
facility should be considered for remedial action. However, we cannot locate
the original contract and thercfore are not able to establish that the contami
nation present st the facility is a result of work done under the Atomic Ene
Comaissicn contract, Consequently, it does not appear that the Department ha
the authority under existing legislation to conduct remedial action. We will
inform you if our ongoing record search results in sisnificant additional
inform tion or if legislation is enacted into Taw which would give the Nepartne
authority to conduct remedial action. In the meantime, we have informed the

Texas Department of Iiealth of the radiological status af your facility (soe

enclosed jetter). Should you have any ouestions, jlease contect Gale Turi (301+.

1)

353-2765) of my staff or myself (391-253-3018).

Sincerely,

Wilitam £. Mott, Mrector

Environrental and Safety
Inoineering Division (EP-14)

Office of Environmental Protection,
Safety, anc Emergency Preparedness

Enclosure
R. W. Ramsey, NE-30)
bec: Steve Miller, GC-34
Aesrospace

EP-<141:GPTurd /dr: 353-2766 :3/11/8) : DF-92

Joh



/72-

FORMERLY UTILIZED SITES REMEDIAL
ACTION PROGRAM INELIGIBILITY REPORT

FORMER MATHIESON CHEMICAL COMPANY (PASADENA CHEMICAL),
PASADENA, TEXAS

Introduction and Summary

An investigation of AEC-related operations at the former Mathieson
Chemica! Company site in Pasadena, Texas, was conducted to determine if the
site was eligible for remedial action under FUSRAP. Records of the AEC Feea
Materials Division stored in Oak Ridge, Tennessee, and in Suitland, Maryland,
were reviewed along with contract ilies. The analysis of information collected
indicated there was insufficient data identified te provide DOE authority to
conduct remedial action at this site. Cursory review of other recoras groups
further indicates that it is not likely that the contract or any other supportive

materials will be found in future records searches.
Reason for Investigation

The Mathieson Chemical Company site was identified as an AEC contractor
during initial FUSRAP investigations. The site was investigated to determine if

it qualified for remedial action.

Background on Mathieson Chemical Company (Pasadena Chemical)
E

Mathieson Chemical Company had a research and development contract
from mid-1951 to mid-1953 with AEC to develop a process for extracting
uranium from the phosphoric acid stream of @ phosphate fertilizer plant. The
contract included bench-scale pilot plant operations and produced less than 50
pounds of uranium. A few memoranda exist that discuss the project or contract

but it appears the contract has been destroyec.


ELIMINATION REPORT
MOBIL MINING AND MINERALS COMPANY
(THE FORMER MATHIESON CHEMICAL COMPANY)
PASADENA, TEXAS

INTRODUCTION

The Department of Energy (DOE), Office of Nuclear Energy, Office
of Remedial Action and Waste Technology, Division of Facility and Site
Decommissioning Projects (and/or predecessor offices and divisions),
has reviewed the past activities conducted on behalf of the Atomic
Energy Commission (AEC) at the former Mathieson Chemical Company (now
Mobil Mining and Minerals Company), Pasadena, Texas. A preliminary
radiological survey revealed some residual contamination in a sink and
drain line that exceeds current DOE radiological guidelines. !
However, on the basis of a review of available historical information,
DOE has determined that it does not have legal authority to conduct
remedial actions at this site. Therefore, this site will not be
included in the Formerly Utilized Sites Remedial Action Program
(FUSRAP) .

This report presents information on the radiological status of the
site and summarizes the results of DOE's authority investigation.
Although the contamination exceeds guidelines, it does not pose a
measurable radiological hazard to site occupants or the general public
under current conditions of site usage.

ly.s. Department of Energy Guidelines for Residual Radioactivity at
Formerly Utilized Sites Remedial Action Program and Remote Surplus
Facilities Management Program Sites (Rev. 1, July 1985).

153


THE AEROSPACE CORPORATION

Sue 4000. 953 L'Enfent Plaze. S$ Wo Wasaimeton. DC 20024 Teiepnone (202) 488-0000

7086-01 .84.aw.%2
8 Marcn 1984

Arcnur Whitman
ce o* Nucl z:
Division of Remedia
U.S. Deparcment of Energy
Germantown, Maryland 20545

Dear Mr, Whitman:
REVIEW OF MATERIAL ON THE PASADENA CHEMICAL CO. (FORMER
MATFIESON HOSTAL CO.) SITE T2 SUPPORT DOE FUSRAP
ELIGIBILITY ANALYSIS

Enclosec piease find a summary repory preparec to suDport your determination
of elicibility or ineligibility for FUSRAP of che former Mathieson Chemical
Co. site in Pasadena, Texas. The material reviewed and collected to sete
contains insufficient information to support inclusion and Sased upon
FForts to identity additional deze, it appears that ‘7 not likely tnat
any material supporting inclusion in FUSRAP wiil be identified in the
syt

: . if it is determined by your office that this site is not eiicible
for FUSRAP, I believe we should meet to discuss she next step in notivyine

the appropriate parties.

o

As you know, Mr. Mijler and you have reviewed 4 prel iminary éraft of tne
enclosure. Mr. Milier nas given tentative approval of tnis version. Fiease

contact me with comments or guestions concerning this materiel.

Sincerely, | 4,

4 i :
fr. fT eK
om “Cc

:
MA TIT. Project Encineer
Environmental Controis and Analysis
Directorate
Eastern Yecnnical Division
Abts
Enclosure
cc: J. Baubl‘tz
if 1 . :
E. Detaney hoes Dec: #. Bauer
co. Jennings {w/c} 3. Fritz
S. Milter F) onocn
~ cr. seen
oe dura (wie)
. M, Jennison
x. Jonson ‘w/e}
P. Marving
re Newmen (wid)
oc. Youne


Did the present owner accept responsibility for the site with knowledge
of its contaminated condition and thet additional remedial measures
are necessary before the site is acceptable for nonrestricted use by the
general public?

There is insufficient data to assess the current owner's responsibility
for any remedial measures if needed.

ee


CONTENTS

Introauction and Summary

Reason for Investigation

Background on Mathieson Chemical! (Pasadena Chemical)
Analysis

Factors Required for Inclusion

Page

nN

(1


Department of Energy .
Washington, D.C, 20545

AUG {1 1981

Mr. Edgar D. Bailey, Director

Division of Licensing,
Registration and Standards

Texas Department of Health

1100 West 49th Street

Austin, Texas 78756

Dear Mr. Bailey:

This is in response to your June 29, 1981, letter regarding the Pasadena
Chemical Corporation site (the former Mathieson Chemical Company). Of
interest to you, this site was designated for remedial action under the
Department's Formerly Utilized Sites Remedjal Action Program on March 19,
1981, because of the possibility that residual radioactive material found
at the facility was a result of work performed under an Atomic Energy Com-
mission contract.

The Office of the General Counsel has reviewed the information in your
June 29th letter. It has reaffirmed its position that the Department does
not have the authority to conduct remedial activities until additional leg-
islation is passed by the Congress. As we stated in our March 27, 1981,
letter, we are unable to establish conclusively that the residual radio-
active material present at the facility is or is not a result of work per-
formed under the Atomic Energy Commission contract. Further, without the
contract, we cannot establish whether the Government-controlled operations
at the site included responsibility for removal of residual radioactive
material.

I am forwarding a copy of your letter to Mr. Robert W. Ramsey, Jr., the
Remecial Action Program Project Leader, in the Office of Nuclear Energy.
Mr. Ramsey is responsible for the conduct of the Department's remedial
activities. You may wish to discuss the Pasadena Chemical Corporation
situation with him (301-353-5272) or with Mr. Steven Miller (202-252-6947)
of the Office of General Counsel.

Sincerely,
ao . -
Ce Lhe Merl
William E. Mott
Office of Operational
Safety (EP-32)

cc: R. W. Ramsey, NE-30.1, USDOE

/ob


159

“: Besadena Chemica Corporation
: P.G BOX 3447

PASADENA. TEXAS 7750"
TELEPHONE (793. £72-364

May 21, 1980

Mr. William E. Mott, Director
Environmental Control
Technology Division

Office of Environment
Department of Energy
Washington, D.C. 20545

Dear Mr. Morr:

This will acknowledge receipt of your letter of May 5, 1980, trrans-
mitting the preliminary radiological data obtained by your contractor
during the survey of a portion of the Pasadena Chemical Corporation
(formerly Olin Corporation) plant site in March of 1980.

As recommended in the contractor's report, we will treat the pilot
plant's sink and accessible drain as contaminated material aud will
dispose of them in an approved burial site if they are removed from
the facility in the future.

Very truly yours,
PASADENA CHEMICAL CORPORATION

oe

L. D. finson
Plant Manager

in

ee: J. L. Murray, Sr.


to Olin Corporation. In 1979, the site was acquired by Pasadena
Chemical Corporation, a subsidiary of Mobil Oi] Corporation. Pasadena
was absorbed by its parent company in 1983 and the name of the
facility was changed to Mobil Mining and Minerals Company. The site
is still used for fertilizer production.

Radiological History and Status

Qak Ridge Operations Office and Oak Ridge National Laboratory
personnel visited the site on November 18, 1977. Results of this
preliminary survey indicated the presence of low-level contamination
jn the sink and drain. Although no real exposure potential exists
under present use, DOE recommended that these structures, when
removed, be handled as contaminated material, and disposed of at an
approved burial site. In May 1980, Pasadena Chemical Corporation
indicated to DOE that the contaminated structures would be disposed of
in the appropriate manner if the structure were modified.

The Texas Department of Health conducted a gamma radiation survey
of the AEC pilot plant area on September 20, 1978. No contamination
was found that could be attributed to the pilot plant operation.

ELIMINATION ANALYSIS

An investigation of AEC-related operations at the former Mathieson
Chemical Company site in Pasadena, Texas, was conducted to determine
if the site was eligible for remedial action under FUSRAP. Records of
the AEC Feed Materials Division stored in Oak Ridge, Tennessee, and in
Suitland, Maryland, were reviewed along with contract files. Analysis
of the information collected resulted in the conclusion that the
available data was insufficient to provide DOE with authority to
conduct remedial action at this site (see March 8, 1984, letter, Wallo
to Whitman, under References below). The contract has apparently been
destroyed in accordance with standard records management procedures.

155°


This elimination report will be archived by DOE through the
Assistant Secretary for Management and Administration. A copy of this
package will be available for public review between 8:00 a.m. and 4:00
p.m., Monday through Friday (except Federal holidays), at the DOE
Public Reading Room located in Room 1£-190 of the Forrestal Building,
1000 Independence Avenue, SW., Washington, D.C.

BACKGROUND.
Site Function

Mathieson Chemical Company had one of a number of research and
development contracts let by AEC from mid-1951 to mid-1953 to develop
processes for extracting uranium from the wet-process phosphoric acid
stream of a phosphate fertilizer plant. The specific objective of the
Mathieson work was to appraise the feasibility of the ammonia
neutralization process developed by the Massachusetts Institute of
Technology. The work included bench-scale pilot plant operations that
produced less than 50 pounds of uranium.

Site Description

The site is located on the Houston Ship Channel near Pasadena,
Texas. The pilot plant was located in a single 12 x 14 ft. room in a
one-story building used as a process development facility and analysis
laboratory. The equipment was removed after the project was completed
(about 1955). The disposition of this material has not been
determined. The room currently contains an L-shaped laboratory bench
(with sink) running along two walls and a chemical hood located on a
third wall, The room is now being used for storage of janitorial
equipment.

Mathieson Chemical Company became Olin Mathieson Chemical
Corporation in August 1954. In September 1969, the name was changed

/s#


/67

Texas Department of Health

Robert Bernstein, M.D., F.A.CP. 1100 West 49th Street Robert A. MacLean, M.D.
Commissioner Austin, Texas 78756 Deputy Commissioner :
(512) 458-7111 Professional Services

Hermas L. Miller,
Deputy Commissioner
Management and Administration

Radiation Control
(512) B35-7000

December 6, 1983

Mr. John Baublitz, Director

Division of Remedial Action Projects
Assistant Secretary for Nuclear Energy (NE-24)
Department of Energy

Washington, D.C. 20545

Dear Mr. Baublitz:

We have noted with interest that the Pasadene Chemical Company, Pasadena,
Texas, has been menrioned in connection with the Formerly Utilized Sites
Remedial Action Program (FUSRAP) in two recent reports: Spent Fuel and
Radioactive Waste Inventories, Projections, and Characteristics
(DOE/NE-0017/2) and Report on the Follow-Up Inspection of the Formerly
Utilized Sites Remedial Action Program (DOE/IG~0199).

From a series of letters between this Bureau and William E. Mott on
March 27, 1981, Jume 29, 1981, and Avgust 1], 198], (copies attached),
we had been led to believe that the Pasadena Chemical Company had been
dropped from consideration in connection with FUSRAP. We are very happy
to see that it has not.

We appreciate an update on the current status of and plans for this site
and any guidance you can provide in resard to what activities this Bureau
should be taking in connection with the site.

Sincerely,
—_t tothe +
Edgar D. BaiYey, P.E., <tor

Division of Licensin,
and Standards
Bureau of Radiation Control

gistration

Enclosures

ec: M. S. Davenport, Pasadena Chemical Company


Hinson, l.D. (Pasadena Chemical Corporation), to W.E. Mott
(Department of Energy), letter of May 21, 1980.

Vierzba, £.A. (The Aerospace Corporation), to W.E. Mott
(Department of Energy), "Comments on the Report Entitled
"Preliminary Survey of Olin Mathieson Chemical Corporation,
Pasadena, Texas," July 16, 1980.

Frangos, T.G. (Department of Energy), to S. Meyers (Department of
Energy), “Designation for Remedial Action of the Pasadena Chemical

Corporation (the Former Mathieson Chemical Company)" March 19,
1981.

Mott, W.E. (Department of Energy), to L.D. Hinson (Pasadena
Chemical Corporation), letter of March 27, 1981.

Mott, W.E. (Department of Energy), to OD.K. Lacker (Texas
Department of Health), letter of March 27, 1981.

Bailey, £.D. (Texas Department of Health), to W.E. Mott
(Department of Energy), letter of June 29, 1981.

Mott, W.E. (Department of Energy), to £.D. Bailey (Texas
Department of Health), letter of August 11, 1981.

Bailey, £. (Texas Department of Health), to J. Baublitz
(Department of Energy), letter of December 6, 1983.

Baublitz, J.E. (Department of Energy), to £.D. Bailey (Texas
Department of Health), letter of January 26, 1984.

Wallo III, A. (The Aerospace Corporation), to A. Whitman
(Department of Energy), “Review of Material on the Pasadena
Chemical Co. (sic) (Former Mathieson Chemical Co.) Site to Support
DOE FUSRAP Eligibility Analysis," March 8, 1984.

/57



The site is Jocatec on the Houston Ship Channe! near Pasadena, Texas. The
pilot was locatec in a single room in @ one-story building used as a process
development facility and analysis laboratory. The equipment was removed after
the project was completed (about 1955), The room currently contains an
L-shapec laboratory bench (with sink) running along two walls and a chemical
hood locate on a thirc wall, The room is now being used for storage of janitorial

equipment.

Mathieson Chemical Company became Olin Mathieson Chemica! Corporation
in August 1954. In September 1963, the name changed to Olin Corporation. The

site is now owned by Pasadene Chemicai Corporation.

Oak Ridge Operations Office and Oak Ridge National Laboratory personne!
visited the site on November 18, 1977. Results of this preliminary survey
indicated the presence of low-level contamination in the sink and drain.
Although no real potential for exposure to persons under present use exists, it is
recommended that these structures, when removed, be handled as contaminated

material, anc disposed of at an approved burial site.

The Texas Department of Health conducted a gamma ray radiation survey of
the old Atomic Energy Commission pilot plant area on September 20, 1978. No
contamination was found that could be attributed to the pilot plant operation.

The current owner of the facility has indicated to DOE that the
contaminated structures will be disposed of in the appropriate manner if the
Structure is modified. The Department of Energy (DOE) has notified the State of

Texas of the findings at this site.

Analysis

Only minime] records on this site were identified. The data reviewed to date
does not indicate that DOE predecessor agencies had any responsibility for this
site other than supplying some suppilementai funds for the development of a

process 10 extract uranium from phosphoric acid. Ne contract for this operation

1/3


Page _//7
NEW EVIDENCE

EXHIBIT J

FORMERLY UTILIZED SITES REMEDIAL ACTION PROGRAM ~ ELIMINATION
REPORT FOR MOBIL MINING AND MINERALS COMPANY (THE FORMER
MATHIESON CHEMICAL COMPANY) PASADENA, TEXAS

This included comments on the report entitled “Preliminary Survey of Olin Mathieson

Chemical Corporation, Pasadena, Texas” which was made November 18, 1977. (See
Exhibit I above.)

This is new evidence and refers to the survey made November 18, 1977. The letter dated
16 July 1980 from Mr. Edmund A. Vierzba,,, Environmental Control and Analysis
Directorate to Dr. William E. Mott, U. S. Department of Energy asks questions that
should have been answered in the 1950s. This letter indicates the possibility that
conditions in the plant could have been more harmful than reported by the Company. It
seems that some information has finally come out about the work that was kept so secret.
Now, the Company seems to be more receptive to the fact that work done under the
uranium contract (or contracts) could have contributed to the conditions of the hazardous
materials in the 240 acre pile of radioactive waste. Nobody knows what to do with this
contaminated pile of waste materials. No one wants to take responsibility for it. It is so
big. It seems that it cannot go anywhere except to an approved disposal site. In the
meantime, it is dangerous and could contaminate the ground water or the Houston Ship
Channel. This appears to be the same problem that Blockson Chemical Company in
Joliet, Illinois and Hematite near St. Louis, Missouri (among others) have had with their
radioactive waste. It is interesting that all of these companies were basically in the same
business, yet no records of contracts or anything else can be found for Mathieson
Chemical Company, Pasadena, Texas. Blockson Chemical Company and Hematite have

been designated as additions to the Special Exposure Cohort. Comments in other exhibits
make reference to this Exhibit J.

Attachments:

(1) Formerly Utilized Sites Remedial Action Program — Elimination Report for
Mobil Mining and Minerals Company (The former Mathieson Chemical
Company) Pasadena, Texas

(2) Letter dated May 21, 1980 from Mr..L. D. Hinson, Pasadena Chemical
Corporation to Mr. William E. Mott, Department of Energy

(3) Letter dated 16 July 1980 from Mr. Edmund A. Vierzba, The Aerospace
Corporation to Dr. William E. Mott, Department of Energy - Comments
On the Report Entitled “Preliminary Survey of Olin Mathieson Chemical
Corporation, Pasadena, Texas”


/60

COMMENTS ON THE REPORT
ENTITLED “PRELIMINARY
SURVEY OF OLIN MATHIESON
CHEMICAL CORPORATIOK,
PASADENA, TEXAS"

Tne letter report is concise and well-written. A question and a comment
were raised by the report.

1. Is there any explanation for the high Ac-227 concentration in the sink?
The value of 185 pCi/g appears high for a phosphate operation.

2. It is not clear from the report that only the bench, drain-line and
sink were found to have surface contamination above background. It
should be stated that the floor and walls were found within typical
backgrounc levels, if such is the case.


L57

Z
THE AEROSPACE CORPORATION wes
Se

20030 Century Blvd., Germantown, Maryland 26767, Telephone: (30! ) 428-2706

7848-02. 80.e2v.13
16 July 1980

Dr. William E. Mott i
Acting Director

Environmental & Safety Engineering

Division

U.S. Department of Energy

Germantown, Maryland 20767

Dear Dr. Mott:

COMMENTS ON THE REPORT ENTITLED
“PRELIMINARY SURVEY OF
OLIX MATHIESON CHEMICAL

CORPORATION, PASADENA, TEXAS"

Aerospace hes reviewed the letter report cited above. Our comments are
attached.

In view of the fact that the State of Texas would like additional survey
assistance from the Department of Energy, and in view of the minor
contamination found, it is suggested that no survey be conducted until
after removal of the sink and drain-line is completed.

The site is currently used, but mainly for storage purposes. Contrary
to the plans at the time of the survey, there are no plans to demolish
the building, according to John L. Murray, Jr., Manager of Environmental
Affairs with Pasadena Chemical Corporation.

There is the possibility that this site may warrant consideration as a
candidate for remedial action. It is also recommended that the State be
notified of suggested restrictions regarding the removal of the sink and
drain-line.

If you have any questions on the attached comments, please contact me at
428-4716.

Sincerely,

Chit 4 ing te

Edmind A. Vierzba
Environmental Control and Analysis

Directorate
EA\/pa
Attachment - as stated
ce: J. Counts bee: T. Iura (w/o)
D. Mayhew A. D. Abbott (w/o!
Cc. D. Jackson F, WwW. Hoch
A. Abriss R. L. Johnson (w/¢
L. C. Brazley S. Rosenzweig (w/t
R. Cooperstein WK. McNulty
A. Whitman J. §S. Dock
R. Barber A, Wallo III
Cc WD Yen —____



Cursory review of other records groups indicates that it is not likely
that duplicates of the contract or any othér supportive materials will

be found in future records searches.

Some conclusions may be reached based on information and contracts
relating to phosphate operations at other sites that are available.
In general, the phosphate contracts were intended to support
industrial research. The contractor usually owned the facilities.
There was no direct AEC involvement other than review of the data.
AEC had an obligation to purchase any uranium produced, but had no
responsibility for the operation. of the sites or their final
condition. The contractors were handling the same materials they
normally handled jin their everyday operations and AEC provided no
special guidance (other than that pertaining to uranium accountability
if any was to be produced). For the same reason, AEC did not specify
any requirements for cleanup.

Based on the information summarized in this report, DOE's Division
of Facility and Site Decommissioning Projects has determined that it
does not have authority to conduct remedial action at the former
Mathieson Chemical Company if it were determined to be necessary and
has eliminated the site from further consideration under FUSRAP. The
Texas Department of Health has been informed of the status of the site
and will oversee any remedial action taken by the site owner, Mobil
011 Corporation. The Environmental Protection Agency will also be
informed of the DOE authority decision.

REFERENCES

o Kaufman, H.E. (Olin Chemicals Group), to W.E. Mott (Department of
Energy), letter of April 12, 1979.

o Oak Ridge National Laboratory, “Preliminary Survey of Olin
Mathieson Chemical Corporation, Pasadena, Texas," March 1980.

(56


FORMERLY UTILIZED SITES REMEDIAL
ACTION PROGRAM INELIGIBILITY REPORTS

PASADENA CHEMICAL COMPANY, PASADENA, TEXAS

10


Department of Energy
Washington, D.C. 20545

JAN 8 i336

Mr. John Murray

Manager of Environmental Affairs
Mobil Mining and Minerals Company
P.O. Box 3447

Pasadena, Texas 77501

Dear Mr. Murray:

The Department of Energy (DOE), as part of its Formerly Utilized Sites
Remedial Action Program (FUSRAP), has reviewed information on the Mobil
Mining and Minerels Company (formerly Mathieson Chemical Compeny) to
determine whether it contains residual radioactivity traceable to
activities conducted on behalf of the Atomic Energy Commission (AEC) (a
predecessor to DOE). The enclosed radiological survey indicated that a
sink and associated drain ana workbench area are contaminated with uranium,
actinium, and radium. However, available information regarding the nature
of the operations and the contractual relatianship between AEC and
Mathieson is not sufficient to establish DOE's authority under the Atomic
Energy Act of 1954, as amended, ta perform any remedial action required at
the site. Therefore, DOE is eliminating it from further consideration
under FUSRAP. It should be noted that the survey data indicated that the
contamination does not pose a significant health hazard to workers or the
general public under the use af the site at the time of the survey.
However, in accordance with Department policy, the Environmental Protection
Agency and the State of Texas Department of Heaith are being notified and
provided a copy of the survey report by copy of this letter so that they
may take whatever action they deem appropriate.

The information supporting this decision will be archived by DOE, and a
copy of the elimination report will be available for public review between
8:00 a.m, and 4:00 p.m., Monday through Friday (except Federal holidays),
at the DOE Public Document Room located in Room 1£-190 of the Forrestal
Building, 1000 Independence Avenue, S.W., Washington, D.C,

/7e


CONTENTS

* INTRODUCTION
BACKGROUND
Site Function
Site Description
Radiological History and Status
ELIMINATION ANALYSIS

REFERENCES

Pw

[52


1B

Department of Energy
Washington, D.C. 20545

MAR 27 1981

Mr. David K. Lacker, Director

Division of Occupational Health
and Radietion Control

Texas Department of Health

1100 West 49th Street

Austin, Texas 78756

Dear Mr. Lacker:

On April 4, and October 30, 1980, 1 transmitted information to you on the
Pasadena Chemical Corporation (the former Mathieson Chemical Company) and the
Department of Energy Program for sites formerly used by the Manhattan Engineer
District and Atomic Energy Commission (AEC) in the Nation's nuclear energy
program. Based on the enclosed radiological survey report of the Pasadena
Chemical Corporation site, the Department has determined that the facility
should be considered for remedial action.

The Mathieson Chemical Company was operated under an AEC contract in the early
1950's; however, we are unable to locate the contract. Because it has not been
established that the residual radioactive material present at the facility is a
result of work performed under the AEC contract, it does not appear that the
Department has the authority under existing legislation to conduct remedial
activities. Accordingly, we recommend that the Texas Department of Health
assume responsibility for regulating the residual radioactive material at the
facility.

Please contact Gale Turi (301-353-2766) of my staff or myself (301-353-3016) for
any further discussion of this matter that you feel necessary.

Sincerely,
‘ ff, ste
William E. Mott, Director
Environmental and Safety
Engineering Division (EP-14)
Office of Environmental Protection,
Safety, and Emergency Preparedness

Enclosure


165°

Mr. William E, Mott
June 29, 1981
Page 2

Although we disagree with you about who is responsible for remedial action
at this site, we are prepared to work with DOE and the company in
every way we can to get the site decontaminated as soon as possible.

Sincerely,

vision/of Licensing, Registration
and Standards

ce: G, Wayne Kerr, USNRC
M.S. Davenport, Pasadena Chemical Corporation


FORMERLY UTILIZED SITES REMEDIAL ACTION PROGRAM

ELIMINATION REPORT
FOR
MOBIL MINING AND MINERALS COMPANY
(THE FORMER MATHIESON CHEMICAL COMPANY)
PASADENA, TEXAS

Department of Energy
Office of Nuclear Energy
Office of Remedial Action and Waste Technology
Division of Facility and Site Decommissioning Projects

15


has been identified. It appears the process under development belonged to

Mathieson and it does not appear that it was developed beyond the research ang
developmen: (R&D) stage. Contamination found on the site could be the result
of the process R&D work because it is higher in uranium than in radium as would

be expected from the process being developed.

Factors Required for Inclusion

During records searches and analysis to support DOE determinations
regarding authority for remedial action, the need for and pertinence of specific
materials are assessed considering five questions used by DOE in an authority
review. A summary of the questions and implications of the data collected to

date with regard to the questions are provided below.

i, Was the site/operation owned by 2 DOE predecessor or did a DOE
predecessor have significant control over the operations or site?

The site was not owned, operated or controlled by DOE predecessors.

2. Was a DOE predecessor agency responsible for maintaining or ensuring
the health and safety and environment at the site (i-e., were they
responsible for cleanup)?

There is no evidence to indicate DOE was responsible for site health,
safety, or cleanup.

3. Is the waste, residual, or radioactive material on the site the result of
DOE predecessor related operations?

It cannot be conclusively determined that the contamination in the
drains resulted from AEC contract works however, it is possible.

4, Is the site in need of further cleanup and was the site left in
unacceptable condition as a result of DOE predecessor related
activities?

Drains are contaminated with uranium and its daughter products in
excess of NRC guidelines for surface contamination at facilities

released for unrestricted use; however, they presently pose no health
hazard.

(1


(ye

(4) Letter dated March 19, 1981 from Mr. Thomas G. Frangos, Department of
Energy to Mr. Sheldon Meyers, NE-30, Department of Energy

(5) Letter dated March 27, 1981 from Mr. William E. Mott, Department of
Energy to Mr. L. D. Hinson, Pasadena Chemical Corporation

(6) Letter dated March 27, 1981 from Mr. William E. Mott, Department of
Energy to Mr. David K. Lacker, Texas Department of Health

(7) Letter dated June 29, 1981 from Mr. Edgar D. Bailey, Texas Department of
Health to Mr. William E. Mott, Department of Energy

(8) Letter dated August 11, 1981 from Mr. William E. Mott, Department of
Energy to Mr. Edgar D. Bailey, Texas Department of Health

(9) Letter dated December 6, 1983 from Mr. Edgar D. Bailey, Texas Department
of Health to Mr. John Baublitz, Department of Energy

(10)Letter dated January 26, 1984 from Mr. John E. Baublitz, Department of
Energy to Mr. Edgar D. Bailey, Texas Department of Health

(11)Letter dated 8 March 1984 from Mr. Andrew Wallo, III, The Aerospace
Corporation to Mr. Arthur Whitman, Department of Energy with “Review of
Material on the Pasadena Chemical Co. (Former Mathieson Chemical Co.)
Site to Support DOE FUSRAP Eligibility Analysis”

(12)Letter dated January 8, 1986 from Mr. Edward G. Delaney, Department of
Energy to Mr. John Murray, Mobil Mining and Minerals Company
(Formerly Mathieson Chemical Company site)


DOE F 1325.10

(7-79)

If you have any questions regarding thi
301-353-4716.

Enclosure

cc: w/enclosure

k. Snyder, EPA/HQ, Wash., D.C.

L. Wright, EPA Region VI, Dallas, Texas
E. Bailey, Texas Dept. of Health

bee:

E. Keller, OR
B. Berven, ORNL
S. Miller, GC-11
Aerospace

Baublitz RF
NEG (4)

s decision, please call me on

Sincerely,
A

Edward G. DeLaney, Director
Division af Facility and Site
Decommissioning Projects

Office of Nuclear Energy

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EP-143

Designation for Remedial Action of the Pasadena Chemical Corporation (the
Former Nathfeson Cher{cal Company)

Shetdon Meyers, NE=30

The former Mathieson Chemical Company, Pasadena, Texzs (presently called
Pasadena Chemical Corpuration), ts hereby designated for remedial action under
the Formerly tttilized Sites Remedial Action Program. We note that this fecili
was utilized under an Atomic Energy Commisston (AEC) contract for a period
during the early 1950's; however, we have not been able to locate the contract
Because {t has not been established that the contamination present is a rasult
of work done under the AEv contract, 4t does not appear that the Department
has the authority under existing legislation to conduct remedial action. If
our ongoing record search should result in any additional information on this E
facility we will notify you.

In view of the location and magnitude of the contamination involved, we reco;
that if remedial action is taken at the facility it be alven a low priority.
Attached for your use is a preliminary survey of the facility and a letter frop
the plant manager jn which he commits to treating the plant's sink and ¢r2in
(oniy contaminetion found during the survey) &8 Contaminatec materval. we arc}
notifying the Texas Repartment of Health of the s{tuation at the facility and
recommending that they assume responsibility for its regulation,

sloned

Thornes G. Frano-s, Director
Office of Envirsnmental
Compliance and Overview (EP~15)

2 Attachments

tc: Fred Haywood, ORNL
William Bibb, OR oe

bee: § idler, GC-34
EP-141 :GPTuri :dr:353-2766: 3/11/81 :DF-92

ei Ah é



ay
Texas Department of Health

Robert Bernstein, M.D. F.A.C.P. 1100 West 49th Street Robert A. MacLean, M.D,
Commissioner Austin, Texas 7B756 Deputy Commissioner

(512) 458-7111

June 29, 1981 TK.

Mr. William E. Mott, Director

Environmental and Safety
Engineering Division (EP-14)

Office of Environmental Protection,
Safety, and Emergency Preparedness

Department of Energy

Washington, D.C. 20555

Dear Mr. Mott:

Thank you very mich for your letter of March 27, 1981, to David K. Lacker
Tegarding the Pasadena Chemical Corporation (the former Mathieson
Chemical Company) site.

We are disturbed that you feel that this site is not eligible for
Department of Energy (DOE) remedial activities. It is our opinion
that the contamination present at the site is a direct result of

the Federal govermment's nuclear energy program conducted under the
auspices of the Manhattan Engineer District (MED) and the Atomic Energy
Commission (AEC). .The Preliminary Survey attached to your letter
clearly reflect the presense of radionuclides that one would expect to
be associated with an uranium recovery facility of that time period.

Historical documents and interviews indicate that the pilot uranium
recovery unit and associated support facilities were phased out around
1955, about 8 years before the State of Texas assumed regulatory control
over radioactive materials in 1963. <A review of our license files
indicates that Texas Radioactive Material License No. 4-742 was issued
on September 23, 1964, based upon an application from the company dated
June 3, 1964, This license was for the possession and use of a 500
millicurie Cesium-137 sealed source in a Nuclear Chicago Corporation
gauge. At no time from then wtil the license was terminated on

August 19, 1981, was any other radionuclide authorized by Texas license.

Based upon our investigation of this, site, we cannét help but conclude,
even in the absence of copies ef contracts between MED or AEC and
Mathieson Chemical Company, that the radioactive contamination measured
at the facility exists as a result of the contact work performed by
Mathieson Chemical Company for MED/AEC. Therefore, we cammot accept your
lied conclusion that DOE has no responsibility for remedial action
at the site. We fail to see how the inability te locate paperwork can
in any way relieve DOE of its legal responsible (or authority) to
conduct remediel action activities at this site.

BrI2zrce