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Engelhard

Engelhard Corp.
contaminated site
Plainville, MA

NRC-SDMP
fuel fab


A former SDMP site transferred to Massachusetts on 3/97 when it became an Agreement State. This site is now a RCRA Corrective Action site. Located at 30 Taunton Street (Route 152) in Plainville, Massachusetts, this 39 acre site was formerly operated by the Makepeace Division of Engelhard Industries, Inc. (Engelhard) for the fabrication of nuclear fuel elements under the U.S. Atomic Energy Act (AEC) from 1957 to 1962. Manufacturing operations involved the use of natural, depleted, and enriched (~ 4%) uranium

Following decontamination and close out surveys by the Engelhard, and confirmed by the AEC, in 1963, the licenses were terminated. From the early 1960's until facility closure in 1993, operations consisted of non-nuclear metal fabrication and finishing, using mostly silver and gold, resulting in waste generation (and soil contamination) that include: PCB's, cyanide, chromium, and acid/alkaline waste streams, solvents, pollution control dust, and metal hydroxide sludge. A smaller metal finishing business is currently operating at the site. In March 1986, EPA issued a RCRA 3007 letter to Engelhard requesting information about the Solid Waste Management Units (SWMUs) and releases of hazardous constituents to the environment. Engelhard responded in September 1986. Starting in 1987, as result of the RCRA 3007 letter, Engelhard voluntarily conducted three phases of environmental investigations to assess the impacts to the soil, surface water, groundwater, etc. from the release of the hazardous constituents to the environment. Some mitigating implementations include demolishing several on-site buildings, installation and operation of a 50 gallon/minute groundwater pump and treat system, and purchase and demolition of several private homes. In 1991, EPA prepared an RFA for the site which included a review of the state and local files, EPA Region 1 files, the 3007 letter response, and visual site inspections conducted on May 26, 1998 and March 25, 1991. In 1993, Engelhard and EPA signed a 3008(h) consent order to perform an RCRA Facility Investigation (RFI) and risk assessments, and implementation or four stabilization measures. The only outstanding stabilization measure is the removal, treatment, and/or capping of contaminated soils in the south side of the building - known as Area of Concern B (AOC B). In 1997, Engelhard submitted to EPA a Conceptual Design for the stabilization of contaminated soils in AOC B, which proposes to encapsulate - into an engineered cell - the low level metal and PCB-containing soils from AOC B and 7 into the AOC 7 (courtyard) area of the site. EPA accepted the Conceptual Design on September 30, 1997, and required the Final Design for AOC B/7 soils to now address RCRA, RSCA, and radiological soils in an integrated design approach. In 1998, the Massachusetts Radiation Control Program (MRCP) conditionally accepted the engineered cell concept. The condition of acceptance was that Engelhard demonstrate that groundwater either flowing off-site, or collected treated and discharged into adjoining Turnpike Lake under USEPA permit, did not contain radiological constituents in concentrations exceeding regulatory standards. In January and June 1999, Engelhard collected and analyzed two rounds of groundwater data which demonstrated that concentrations were within regulatory standards. These samples were summarized in a letter to the MRCP and the EPA on November 5, 1999. On July 6, 2001, Engelhard submitted to the EPA a Preliminary Design Report (PDR) for AOC B stabilization measures. This report was prepared specifically to address EPA's comments regarding the Engelhard's Draft RFI report of September 1999, concerning unacceptability of 74 ppm of PCB cleanup standard. In July 2001, Engelhard submitted a Preliminary Design Report (PDR) to EPA and MRCP for the AOC B Soil Stabilization Project. After comments from MRCP and the EPA, on December 5, 2002 Engelhard proposed to undertake the AOC B Soil Stabilization Project in a comprehensive approach. Specifically, Engelhard provided: 1) Supplemental soil and Groundwater sampling and analysis, and groundwater hydrological evaluation in potential source area AOC 7; 2) Historical review of the activities since the Decommissioning Work Plan of 1997; 3) Respond to EPA regarding adjacent areas to AOC 7 and 16. Additionally, an appendix to the December 5, 2002 letter, entitled "Draft Work Plan for AOC 7 SDI" included field activities to investigate additional EPA concerns regarding VOC's, metal, and PCB's as well as radiological waste constituents prompted the MRCP to require a Radiological Health and Safety Plan (RadHASP) to define personal protective equipment, instrumentation, training, and response measures when encountering radiological activity above background. In the July 2004 report "Supplemental Design Investigation Courtyard Area (AOC 7)", Engelhard summarized their finding from implementing the SDI program and provided their recommendations for proceeding forward. 1) The SDI program was performed from December 12-23, 2003, whereby 26 soil boring location were completed to a depth of from 6'-18' below grade surface (bgs) within the courtyard area and on adjacent former building slabs. The SDI data identified the need for additional soil investigation boring which occurred from March 4-12, 2004. 2) VOCs, PCBs and radionuclides were found above action limits, thus, Engelhard recommended the further investigation and remediation efforts for the VOCs, PCBs and radionuclides. Specifically, the radiological recommendation was for Engelhard to evaluate acceptable residual soil contamination guideline values (i.e., DCGLs) for uranium radioactivity in site soils in accordance with RCP regulatory requirements. In a February 24, 2005 report, "Future Land Use Proposal Application," Engelhard concludes that the presence of VOCs in fractured bedrock beneath the Site dictates that the site be restricted to an industrial/commercial use. It is also Engelhard's intent under the industrial use scenario to manage low level contaminated soils on-site in an engineered disposal cell meeting RCRA closure requirements. In the September 7, 2005, report, "Radiological Risk Assessment and Technical Basis for Derived Concentration Guideline Values (DCGLs)," Engelhard presents its view that the soils in AOC B and 16, and the AOC 7 engineered cell, do not exceed the RCP unrestricted release criteria of 10 mrem/yr - using MARSSIMs methodology - except for limited areas beneath the former Building 2 slab and adjacent site areas. Engelhard, at the time of closure of the engineered cell, intends to provide a property deed restriction known as an Activity and Use Limitation (AUL) land use restriction. On February 17, 2006, the MRCP sent notice to Engelhard that their "engineered cell" proposal will be approved based on a restricted release criteria as outlined in the NRC's regulations 10 CFR 20.1403 et. al. and the RCP's - soon to be published - exact copy of these regulation to be found in 105 CMR 120.246 et. al. Thus, Engelhard was asked to submit information from the proposed 120.246(C) through (E), which focus' on the establishment of a Financial Assurance account, Involvement of the affected community (e.g., hearings), and estimation of the dose to the public if the AUL failed. Additionally, Engelhard was asked to submit the RESRAD data inputs and the reports RESRAD generated to support the DCGLs. In June 2006, Engelhard became a wholly owned subsidiary of BASF, who are re-thinking the implementation of an "engineered cell."

ENGELHARD CORPORATION

1. Site Identification

Engelhard Corporation

Plainville, MA

License No.: None

Docket No.: 070-00139 (old)

License Status: Terminated in 1962

Project Manager: J. Parrott

2. Site and Operations

A subsidiary of Engelhard Corporation called D.E. Makepeace was licensed by the AEC to use enriched

uranium for the fabrication of fuel elements from the late 1950's to the early 1960's. During this period, the

licensee was allowed to discharge uranium contaminated effluent to an onsite septic system and to incinerate

uranium contaminated solid waste on site. At license termination, only indoor areas were surveyed for release.

The outdoor contamination was not discovered until the site became subject to characterization for the

presence of hazardous wastes on site under RCRA. Because the contamination was from special nuclear

material, and.therefore not subject to regulation by RCRA, the EPA contacted the NRC in late 1991.

The site is currently operating but does not use licensable material. The majority of the approximately 10

hectare (25 acre) site is covered by buildings and parking lots. This site is adjacent to a small reservoir called

Turnpike Lake. Engelhard is in the process of shutting down this facility.

3. Radioactive Wastes

Very little data exists on the radioactive wastes at this site. Agamma survey was done by Engelhard in 1988on

the buildings that existed at the time that licensed activities took place, and also around the septic system and

pump house. Inside the buildings, maximum readings of 1.8x 1.8E-8 to 2.1E-8 C/kg (70 to 80 _R)/hr were found

in isolated areas. Sludge inside the unused septic tank also was found to be contaminated. Unverified preliminary

sampling in the area of the old septic system have yielded gross alpha values as high as 2.4 Bq (66 pCi)/g in

the soil and 48 Bq (1300 pCi)/l in the ground water. Areas of the site also are contaminated with heavy metals

and organic solvents, so the potential exists for mixed wastes.

4. Description of Radiological Hazard

Access is not controlled to indoor areas suspected of being radiologically contaminated. However, this contamination

is fixed and should be no hazard to plant workers.The suspected outdoor contaminated areas are under

pavement. Access to the old septic tank is possible through a manhole in the parking lot. The radiological

contamination detected so far is confined to the site. non-radiological hazardous waste has been detected in

onsite soil and in ground water and offsite ground water.

5. Financial Assurance/Viable Responsible Organization

Because no license exists for this site, compliance with financial assurance regulations does not apply. Engelhard

appears to be a financially viable company and seems willing to properly decommission this site. Engelhard

has received an administrative order from the EPA Region I RCRA office to characterize and remediate the

hazardous contamination associated with this site.

6. Status of Decommissioning Activities

On November 10, 1992,NRC staff participated in a public meeting in Plainville involving representatives of

EPA Region I, the Massachusetts Department of Environmental Protection (DEP), and Engelhard Corporation.

This meeting was held in conjunction with the release of the Public Involvement Plan prepared jointly by

DEP and EPA. The Public Involvement Plan is applied to sites as designated by DEP in response to community

interest in becoming involved in the remediation process.

NRC sent a letter to Engelhard on November 23, 1992, requesting that all samples taken for RCRA site

characterization be analyzed for gross alpha and gross beta, or isotopic uranium in areas where elevated gross

NUREG-1444

alpha readings have already been found. This letter also outlined the residual contamination criteria that

should be applied to the site soil as 1.113q(30pCi)/I total uranium,and 1.1Bq (30pCi)/I total uraniuminground

water.

Engelhard is currently negotiating with EPA on the specifics of site characterization/remediation under the

RCRA order. So that the characterization/remediation of this site goes as efficiently as possible, NRC is

requesting that Engelhard combine its RCRA site characterization efforts with the site characterization

requested byNRC. However, if the EPARCRAorder processbecomes unreasonablydelayed in the negotiating

phase, NRC will require Engelhard to act independently on the NRC request.

Engelhard submitted a decommissioning plan for the building contamination on April 21, 1993.

7. Other Involved Parties

The EPARegion IRCRA office and Massachusetts DEP are involved at this site because of the hazardous waste

contamination.

8. NRC/Licensee Actions and Schedule

• NRC approves building interior decommissioning plan May 1993

• Engelhard submits radiological site characterization plan concurrent October 1993

with RCRA site characterization plan

• NRC approves site characterization plan December 1993

• Engelhard submits site characterization data and decommissioning plan June 1994

NRC apl_roves decommissioning plan September 1994

• Engeihard completes decommissioning, submits December 1994

verification survey data

• NRC performs confirmatory survey March 1995

• NRC releases site fl_r unrestricted use August 1995

9. Problems/Issues

Possibility for mixed waste at this site.

 

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