Superior Steel Pa 2007 02

User Manual: Superior

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Preliminary Assessment

Superior Steel Corporation

Scott Township, Pennsylvania

Prepared by:

U.S. Army Corps of Engineers, Buffalo District

February, 2007

TABLE OF CONTENTS

1.0 Introduction…….………………………………………………...…….……………............1

2.0 Site Description, Operational History and Waste Characteristics…………………….....3

2.1 Site Description……………………………………………………………………….3

2.2 Owner-Operator Information...………………....……………………….……............3

2.3 Operational History and Waste Characteristics..…….……….........…….......……….4

2.4 Previous Radiological Surveys.………………………..…………………………..…5

2.4.1 ORNL Survey…..…………………………………………………………..5

2.4.2 Applied Health Physics Survey (1).……………………………….………..6

2.4.3 Applied Health Physics Survey (2)………………………………..………..6

2.4.4 ORISE Phase 1 Survey………………………………………….………….7

2.4.5 ORISE Phase 2 Survey…....…………………………………….………….8

2.4.6 ORAU Dose Assessment……………………………….…………………..9

3.0 Soil Exposure and Air Pathways...……………………………………..…………………..9

3.1 Physical Conditions...……………………………………………..………………….9

3.2 Soil and Air Pathways and Direct Radiation..…………………………..…………..10

3.3 Soil Exposure, Air Pathway, and Direct Radiation Conclusions…………….……...11

4.0 Groundwater Pathway...………………………………………………………………..…11

4.1 Hydrogeologic Setting..……...…………………………………………………..….11

4.2 Groundwater Pathways……..…………………………………………………….....12

4.3 Groundwater Pathway Conclusions…...………………………….……………..…..12

5.0 Surface Water Pathway..……………………………………………………………..…...12

5.1 Hydrogeologic Setting…..…………………………………………….………….…12

5.2 Surface Water Pathways…..…….…………………………………….………….…13

5.3 Surface Water Pathway Conclusions……..….....………………………..……….…13

6.0 Combined Pathway Conclusions..……………………………………………………..….13

7.0 Summary and Conclusions…………..…………………………………………………....14

8.0 References…...…………………………………………………………………………..…15

Attachment A – DOE Inclusion Letter

Figures

1.0 Superior Steel Site Location

2.0 Layout of Building 23 Complex Area and Locations of Process Machinery

3.0 Process Layout

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TABLE OF CONTENTS CONTINUED

Tables

1.0 Historical Elevated Soil/Residue Samples

2.0 Surface Activity Levels Building 23 Complex

3.0 Uranium Isotopic Concentrations in Soil Samples

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Abbreviations, Acronyms, and Symbols

AEC Atomic Energy Commission

AHP Applied Health Physics Inc.

Argonne Argonne National Lab

AR Army Regulation

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CFR Code of Federal Regulations

cm centimeter

DOE Department of Energy

dpm Disintegrations per minute

EDR Environmental Data Resources

EPA Environmental Protection Agency

ESSAP Environmental Survey and Site Assessment Program

FUSRAP Formerly Utilized Sites Remedial Action Program

gpm Gallons per minute

MED Manhattan Engineer District

mrem millirem

MOU Memorandum of Understanding

NCP National Oil and Hazardous Substance Pollution Contingency Plan

NEPA National Environmental Policy Act

NIOSH National Institute of Occupational Safety and Health

NRC Nuclear Regulatory Commission

NRCS Natural Resource Conservation Service

NUREG Nuclear Regulatory Guidance

ORAU Oak Ridge Associated Universities

ORISE Oak Ridge Institute for Science and Education

ORNL Oak Ridge National Laboratory

PA Preliminary Assessment

PADEP Pennsylvania Department of Environmental Protection

PENNDOT Pennsylvania Department of Transportation

pCi/g Picocuries per gram

pCi/L Picocuries per liter

RI Remedial Investigation

SAIC Science Applications International Corporation

SSC Superior Steel Corporation

U Uranium

USACE United States Army Corps of Engineers

μR/h microRoentgen per hour

yr year

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1.0 INTRODUCTION

The United States Army Corps of Engineers (USACE) in accordance with the

Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and the

National Oil and Hazardous Substance Pollution Contingency Plan (NCP) performed a

Preliminary Assessment (PA) of the former Superior Steel Corporation site. The purpose of this

PA was to review information to determine the need for further action by USACE under the

Formerly Utilized Sites Remedial Action Program (FUSRAP) to ensure the protection of human

health and the environment. The scope of the assessment included a review of existing

information about the site and a site visit on August 29, 2006.

The former Superior Steel Site in Scott Township, Pennsylvania, processed uranium

metal in support of the U.S. Atomic Energy Commission (AEC) fuel-element development

program from June 27, 1952 to contract termination on September 30, 1957. The uranium-

processing contract originated with the AEC New York Operations Office and later was

administered by the AEC Oak Ridge Operations Office beginning on July 1, 1954. The contract

was transferred to the AEC Savannah River Operations Office on October 15, 1954. Upon

contract termination, the AEC Savannah River Operations Office destroyed the official contract

file in accordance with its records disposition schedule.

In addition to the work performed for the AEC, Superior Steel was licensed in 1956 (No.

C-3480) to receive possession of and/or title to thorium metal for the purpose of forging, roll

cogging, finish rolling, and cutting. This license allowed Superior Steel to receive source

material (thorium metal) from another commercial licensee (Babcock & Wilcox Company under

license No. C-3465) and process it into the desired shape. According to the Nuclear Regulatory

Commission (NRC), the Superior Steel AEC license expired in 1958 and records indicate that

there was neither a closeout survey nor inspection of the facility to support termination of this

license (NRC 2006). Any residual radioactive contamination associated with commercial

operations involving thorium metal is not eligible for cleanup under FUSRAP (Owen 2006).

The primary AEC operations performed at the Superior Steel Site consisted of salt

bathing, rolling, brushing, shaping, cutting, stamping, and coiling of uranium metal. Records

indicate that natural and enriched uranium were processed at the site; recycled uranium from

reprocessed spent nuclear fuel may also have been processed at the site.

In March of 1974, FUSRAP was initiated under the direction of the Atomic Energy

Commission (AEC) and in 1975 was assigned to the Energy, Research, and Development

Administration (ERDA) until 1977, when program responsibility was assigned to the newly

created Department of Energy (DOE). In the Energy and Water Development Appropriations

Act, 1998, (Title I, Public Law 105-62, 111 Stat. 1320, 1326) Congress transferred the

responsibility for the administration and execution of cleanup at eligible FUSRAP sites to

USACE. In the Energy and Water Development Appropriations Act, 2000 (Title VI, Public Law

106-60, 113 Stat. 483, 502), Congress directed that any response action taken under FUSRAP by

the Secretary of the Army, acting through the Chief of Engineers, shall be subject to CERCLA

and the NCP.

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In March of 1999, USACE and DOE signed a Memorandum of Understanding (MOU)

that defined the administration and execution of responsibilities of each party under FUSRAP.

Pursuant to that MOU, when a new site is considered for inclusion in the FUSRAP, DOE is

responsible for performing historical research to determine if the site was used for activities that

supported the Nation's early atomic energy program. If DOE concludes that the site was used for

that purpose, the agency will provide USACE with that determination. USACE is then

responsible for preparing a PA in accordance with the CERCLA process to determine if a

response action is appropriate because of releases related to AEC-related operations.

On 3 February 2006, the DOE provided USACE with a determination that the site was

used for AEC activities that supported the Nation's early atomic energy program (Attachment A).

Accordingly, the former Superior Steel Corporation may be eligible for inclusion into the

FUSRAP, if it is determined under section III.D.2 of the Memorandum of Understanding (MOU)

between the DOE and USACE that further CERCLA response actions may be necessary to

address FUSRAP-related contamination at the site and there is indication that further detailed

analysis will show the Federal Government may be responsible under CERCLA for the

contamination.

The purpose of this PA is to determine whether an unpermitted release or threat of release

of FUSRAP eligible hazardous substances occurred at the site and pose a threat to the public

health or the environment, as defined in Section 101(22) of CERCLA. If the assessment

determines that there is a release or threat of release, which may pose a threat to the public health

or the environment, then CERCLA authorizes further response actions to investigate the site as

necessary. This action does not respond to releases that are federally permitted or addressed by a

legally enforceable license, permit, regulation or order issued pursuant to the Atomic Energy Act

of 1954 or other Federal statute. Response actions may include removal (if imminent threat to

human health or environment) or additional investigation (Site Inspection). If radiological risk is

evident, then the CERCLA process progresses through a Remedial Investigation, Feasibility

Study, Proposed Plan and Record of Decision. If no evidence of release, or threat of release, is

found and no significant threat to the public health or environment is identified to eligible

FUSRAP related contaminates, then the PA will recommend no further action.

In addition to the documents transferred by DOE to USACE referencing Superior Steel,

USACE contracted with Argonne National Laboratory (Argonne) to perform additional records

search. Argonne completed this search in August 2006 and a complete list of records obtained is

located in Attachment 1 of Argonne’s report (Argonne, 2006). Representatives from Argonne

and USACE visited several locations including the National Archives and Records

Administration, the Pennsylvania Departments of Environmental Protection and Transportation,

the Pennsylvania State Archives, and the Pennsylvania State Library. Additionally, Argonne

contacted representatives from the NRC, the DOE Office of Legacy Management, and the

Pennsylvania Department of Health (which subsequently contacted the Agency for Toxic

Substances and Disease Registry). These activities led to the identification of additional records

that were not previously identified in the documents provided by the DOE. Further, a

preliminary legal analysis must show some Federal Government responsibility for the

contamination, based on CERCLA principles of liability, otherwise a recommendation will be

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made that FUSRAP activities be terminated at the site and any necessary cleanup be conducted

under the jurisdiction of an appropriate federal or state agency.

2.0 SITE DESCRIPTION, OPERATIONAL HISTORY AND WASTE

CHARACTERISTICS

2.1 Site Description

The former Superior Steel Site is located in an industrial complex at 500 Superior Street

in Scott Township, Allegheny County, Pennsylvania, (latitude 40.398569, longitude -

80.0096351) about 8 km (5 mi) southwest of downtown Pittsburgh. The Superior Steel site is

located in Environmental Protection Agency (EPA) Region 3. The 25-acre site originally was

occupied solely by the Superior Steel Company and now consists of several separately owned

manufacturing, storage, and office buildings. The site is bounded on the north, west, and south

by Chartiers Creek and on the east by Superior Street (Figure 1). The building that housed the

uranium processing facilities (Building Complex Number 23) is now owned by Superbolt, Inc., a

manufacturer of mechanical stud and bolt tensioners.

Superbolt Building Complex Number 23 consists of five interconnected steel-frame

warehouses (Figure 2) with metal roofs with corrugated steel siding. The floor construction

varies from area to area and is a combination of poured concrete, brick, and bare earth. The

building has a few windows, several garage-type doors, some standard door entrances, and

various roof ventilator fans. Superior Steel used three of the five areas in Building 23 to process

AEC-related material. Superbolt Inc. had previously leased the potentially contaminated areas to

other businesses for use as storage space and limited light industrial activity. However,

Superbolt Inc., discontinued this once the NRC identified residual radioactivity in Building 23.

On August 29, 2006 during a site visit to the former SSC complex, representatives from

Superbolt Inc. indicated that the northern third of Bldg. 23B is leased to a trucking company.

This industrial complex, including Building 23, sustained extensive flood damage on September

18, 2004, when a discharge of 15,900 cubic feet per second occurred on Chartiers Creek (NRC

2006).

2.2 Owner – Operator Information

At the time of AEC contract operations, the company was known as Superior Steel

Corporation (SSC) and later as Copper Weld, Inc. and as Lot and Block 102J210. The buildings

and facilities at the site have been sold a number of times over the intervening years, and other

names associated with the former Superior Steel Site are Lange Machinery Company, Inc., J.G.

Industries, Inc., Carnegie Industrial Park, and Superior Tube Company (ORAU 2005). The

current owner of Building Complex Number 23 is Superbolt Inc., who uses the building for

storage (NRC 2006).

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2.3 Operational History and Waste Characteristics

For the purposes of this assessment, the operational history of the former SSC began with

a unit-price AEC contract that extended from June 27, 1952 through September 30, 1957. The

original SSC contract is unavailable (contract No. AT 30-1-1412), although a contract awarded

to Metals & Controls for similar work was assumed to have the same boilerplate contract articles

(Aerospace Corporation, 1985). The contract originated from the AEC New York Operations

office, later transferred to the Oak Ridge Operations office, and then on October 15, 1954 to the

Savannah River Operations office. According to the Savannah River Operations office, SSC

contract files were destroyed. However, correspondence files relating to the work done by SSC

indicate they rolled, cut, and finished uranium metal into flat plates under a unit-price contract.

In addition to the work performed for the AEC, Superior Steel was licensed in 1956 (No.

C-3480) to receive possession of and/or title to 700 pounds of thorium metal to forge test. The

license was amended one month later for forging, roll cogging, finish rolling, and cutting of

45,000 pounds of thorium ingots for the Babcock & Wilcox Company. However, no

confirmation of receipt or handling of thorium has been found. Due to the limited size of the

Superior Steel facilities and its production capacities, it can be assumed that the both commercial

work and work performed for AEC by Superior was done on the same equipment and process

line. Additionally, it was noted by Aerospace Corporation that work performed for AEC by

Superior Steel occurred on the weekends when the plant would have otherwise been idle,

indicating that commercial work was potentially done on these same equipment lines (Aerospace

Corporation, 1985). The Superior Steel AEC license expired in 1958 and NRC records indicate

that neither a closeout survey nor inspection of the facility was performed to support the license

termination (NRC 2006). Any residual radioactive contamination associated with commercial

operations involving thorium metal is not eligible for cleanup under FUSRAP (Owen 2006).

AEC-contracted work performed by SSC occurred in Building Complex Number 23 (or

Bldg. 23), although only three of the five areas were used for uranium manufacturing activities:

the Mill Area (Area 23A), the Rolling Area (Area 23D), and the Motor Room (Area 23E). While

Areas 23B and 23C were not identified as being used in uranium processing activities, the most

recent radiological survey conducted by ORISE for NRC addressed all five areas and

documented radiological contamination in all five areas (Adams 2003).

Area 23A covers about 2,300 m2 (25,000 ft2) and contained the salt bath, roughing mill,

brushing station, finishing stands, and shear; the majority of the uranium handling and metal

shaping occurred here. All equipment used in this process has been removed and subfloor pits

approximately 2.5 m (8 ft) deep located below this uranium processing equipment are now filled

in with rubble and capped with 15 cm (6 in.) of concrete by previous owners, Lange Machinery

of Coraopolis, Pennsylvania (Myrick, 1981) subsequent to Superbolt Inc owning the site.

Historical reports indicate that the sides of the pits are constructed of concrete but it is

undetermined if the floor of the pits are also of concrete construction due to the debris now

located in the pits. The Adams (2003) report refers to this subfloor feature as consisting of

multiple pits extending the length of the former process layout (Figure 3) in Areas 23A and 23D

(Figure 2), as well as approximately 15 m (50 ft) outside the building north of Area 23A. Area

23A was used later to rebuild coke oven doors and is now a storage area for equipment not

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associated with either the uranium milling or coke door rebuilding processes; about 50% of the

floor space is used for storage.

Area 23D covers about 1,250 m2 (13,000 ft2) and was used to roll metal for shipping to

customers desired specifications. Area 23D is separated from Area 23A by a sheet-metal wall.

There were two pits in the south end of Area 23D that were filled with rubble and finished with

concrete to floor level. A small storage shed that is attached to the west side of Area 23D was

remediated including contaminated soil underneath the shed, in 1997. The north end of Area

23D is used by Superbolt for storing materials and supplies. The south end of Area 23D is

currently empty except for containers filled with radioactive waste from the 1997 remedial action

(storage shed and nearby contaminated soil) and radioactive wastes associated with the ORISE

surveys. These stored wastes are physically separated from the rest of Area 23D by a temporary

wall and are covered with a tarp. Superbolt Inc. uses about 20% of the floor space in this area

for storage.

Area 23E covers about 1,300 m2 (14,000 ft2) and contained the motors and control panels

that powered the mill equipment in Area 23A. This area was considered the clean side of the

mill because the atmosphere was controlled to provide proper operating conditions for the

motors and instruments. About 30% of the floor space is currently being used for storage

purposes.

Areas 23B and 23C were not used in the uranium processing activities conducted by

Superior Steel. Area 23B covers about 1,760 m2 (19,000 ft2) and Area 23C about 920 m2 (9,900

ft2). Superbolt used Area 23B to store the waste from the 1997 remedial activities, which were

relocated to the south end of Area 23D and consolidated with wastes generated during the

ORISE surveys. About 10% of the floor area in Area 23B is used by Superbolt to store supplies.

Area 23C is generally empty, with less than 10% of the floor space used by Superbolt to store

materials and supplies. A small trailer, which belongs to the trucking company, is parked in the

north end of the building.

2.4 Previous Radiological Surveys

Five radiological surveys of Superbolt Building Complex Number 23 have been

documented.

2.4.1 ORNL Survey

Oak Ridge National Laboratory (ORNL) performed the first survey conducted of the SSC

site in July 1980 at the request of the Department of Energy. The purpose of the survey was to

provide information on the present condition and use of the former mill area and to determine the

need for a detailed survey of the site. The survey report concluded that uranium contamination

was found in the Mill Area (Area 23A), the Rolling Area (Area 23D), and in the storage shed

adjacent to the Rolling Area. Elevated gamma exposure rates were measured up to 500

microroentgens per hour (μR/hr) in the pits of the Rolling Area, and a soil sample from the

bottom of a pit had a measured uranium-238 (U-238) concentration of 5,800 picocuries per gram

(pCi/g). Gamma exposure rates in the storage shed were measured up to 400 μR/hr, and a soil

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sample collected from beneath the wood floor had a U-238 concentration of 1,100 pCi/g. The

full extent of contamination could not be determined in the survey areas due to the thick coke

dust and residue on horizontal and vertical surfaces, heavy equipment and other stored materials

on the floor, and rubble in the subfloor pits. The transmittal letter for this report recommended

that a more complete survey be performed to determine the full extent of radioactive

contamination at the site (Myrick and Clark, 1981).

2.4.2 Applied Health Physics (1)

The second radiological survey was performed at the request of the site owner Superbolt

Inc. The survey was performed on April 15 and 16, 1997 by Applied Health Physics (AHP)

under a contract with Superbolt’s environmental contractor, Environmental Assessment

Company. The goal of the survey was to provide a preliminary radiological characterization of

the former SSC site. The AHP survey included gamma-exposure rate measurements and surveys

of removable surface contamination. Swipes of accessible areas were taken throughout the

facility; no area was identified as having removable contamination in excess of NRC regulatory

limits for unrestricted release. Accessible areas included tops of brick walls (up to 8 feet), wall

penetrations, floor drains, in the Mill area. Inaccessible areas were classified as overhead

surfaces to include crane beams and the covered pits in the Mill Area.

The measured gamma exposure rates at 1 m (3 ft) above the floor in the Mill Area (Area

23A), the Rolling Area (Area 23D), and the Motor Room (Area 23E) were at reported

background levels. Peripheral gamma radiation surveys of areas outside Building 23 included a

storm drain on the southeast corner of the Mill Area (the likely outfall for the Mill Area cooling

pits) and a cursory gamma radiation survey of the general property, including the banks of

Chartiers Creek. These measurements were conducted at 1 m (3 ft) above the ground surface

and showed no elevated gamma radiation levels (AHP, 1997a).

However, elevated gamma radiation levels were detected at the storage shed by the

Rolling Area, which was confirmed by sampling for uranium. A contact gamma-radiation

exposure rate of 40 to 60 μR/hr was measured in the southwest section of the storage shed.

Elevated gamma exposure rates of 20 μR/hr at 1 m (3 ft) above the ground and contact readings

ranging from 100 to 200 μR/hr were identified in soil on two sides of the shed. Removable

contamination swipes taken in the storage shed identified slightly elevated levels of alpha

contamination, that were below the NRC limits for unrestricted release (AHP, 1997a).

Applied Health Physics Inc. in conjunction with PADEP representatives concluded that

due to the levels of radiation and contamination identified in and surrounding the storage shed

that a more in depth analysis of the storage shed and surrounding area would need to be done.

2.4.3 Applied Health Physics (2)

Superbolt Inc., following the recommendations in AHP’s radiological characterization

survey contracted with AHP to perform additional radiological characterization of the storage

shed area. Applied Health Physics Inc., returned during the summer and fall of 1997 and

focused on the storage shed by the Rolling Area, which exhibited radioactive contamination

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above NRC limits for unrestricted release. Surveys for removable surface contamination were

conducted in the storage shed during July 1997 and no values in excess of NRC regulatory limits

were identified. Elevated levels of gamma radiation were measured above the storage-shed floor

and portions of the concrete floor were removed to evaluate the underlying soil. A gamma

screening of the surface soil identified elevated readings throughout this area at depths up to 0.76

m (2.5 ft) (AHP, 1997b). Applied Health Physics Inc. along with PADEP representatives

recommended that the storage shed and the soil underneath be remediated to a depth of at least

four feet.

The storage shed and adjacent contaminated soil area were remediated and the resultant

wastes placed in containers, which were stored in Area 23D at the conclusion of the remedial

effort. Two additional contaminated areas identified by PADEP in the Rolling Area (Area 23D)

also were remediated. About 13 m3 (465 ft3) of radioactively contaminated soil and concrete

(including the floor of the storage shed) were removed during the remedial actions conducted

during October and November of 1997. This radioactive waste was placed in five B-25

containers and two 55-gallon drums and moved to Area 23B for storage; these wastes were

subsequently moved to the south end of Area 23D. Follow-up surveys of the remediated areas

were performed by AHP, who applied release criteria of twice the background gamma exposure

rate of 9 μR/hr and a total uranium concentration of 30 pCi/g in soil. Several values exceeding

these criteria are indicated in AHP’s Field Service Report Dated December 2, 1997 (AHP,

1997c).

2.4.4 ORISE Phase 1

In April 2000, the NRC’s Division of Nuclear Safety, Region I Office requested that the

Environmental Survey and Site Assessment Program (ESSAP) of ORISE perform a radiological

scoping survey. The focus of the scoping survey was on various portions of the SSC site on

those areas not previously addressed by the NRC, PADEP, and AHP. The fourth survey was

performed by ORISE in Areas 23A, 23E, and 23D from August 28 through September 1, 2000.

This Phase 1 survey of the three areas that records indicate were used by Superior Steel in its

uranium processing activities included alpha, beta, and gamma scans, as well as surface beta

activity measurements, gamma-exposure rate measurements, soil sampling, and debris sampling.

Results of this survey indicated that significant residual surface contamination remained at the

site on the horizontal structural surfaces (floor and overhead beams) within Area 23D and in soil

at various locations throughout the interior and exterior of the three surveyed areas; surface

activity measurements were not taken in Areas 23A and 23E.

The gamma exposure rates measured at five locations in the southern portion of Area

23D were at background levels. However, the surface total beta activity levels on the floor of this

area ranged up to 170,000 disintegrations per minute per 100 square centimeters (dpm/100 cm2),

with lower (but elevated) levels reported for the lower walls and overhead beams. Gamma

surface scans were conducted on approximately 75% of the available exterior area out to 5 m (16

ft) from the exterior walls on the east, west, and south sides, and out to about 20 m (66 ft) along

the north end of the facility. There is no indication that the survey covered any of the exterior

building surfaces up to and including the roof of the structure. Elevated gamma exposure rates

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were identified near the former storage shed and on the north side of the facility near the salt-

bath area.

Soil and debris samples were collected by ORISE and analyzed for uranium-235 (U-235)

and U-238 by gamma spectroscopy. Six locations in the subfloor pits were exposed by removing

the flooring and backfill, and soil samples were collected from four of the six excavations; most

of the removed material was returned to the pits. The ORISE report did not specify the depths at

which samples were taken from the pits; a general statement is made in the beginning of the

report stating that the pits were assumed to be approximately 2.5 meters deep. In addition, cores

were drilled through the floors of Areas 23A, 23E, and 23D, and through the asphalt and a

roadway surrounding the facility to allow for the collection of soil samples. All areas were

repaired as appropriate following collection of samples. Forty-six soil samples were collected

including those from the three excavated pits in Area 23A, one excavated pit in the salt bath area,

and randomly selected locations inside and outside the facility. All areas were repaired as

appropriate following collection of samples.

Many of the samples had measured uranium concentrations that were comparable to

naturally occurring background levels. Table 1 presents the elevated soil sample results from

this survey. The maximum reported U-238 concentrations of 7,180 pCi/g was collected from a

soil sample in the salt bath area of Area 23A. The U-235 concentration for this sample was

reported as 529 pCi/g. Five soil samples also were analyzed by alpha spectroscopy and produced

concentration ratios of uranium-234 (U-234) to U-238 of essentially one (unity) results are

presented in Table 3 (Adams, 2001). The ORISE report does not give the sample locations of

the five alpha spectroscopy analyzed samples. An examination of nuclide ratios is inconclusive

as to whether enriched uranium exists at the site.

The ORISE report concluded that the results of its survey indicated that significant

residual contamination remains at the site within the soils at the north and southwest ends (salt

bath and storage shed areas) of the exterior of the facility and on the horizontal surfaces within

the Bldg. 23 complex.

2.4.5 ORISE Phase 2 Survey

The NRC’s Division of Waste Management requested that ESSAP of ORISE perform

additional radiological evaluations of portions of the SSC complex. The fifth survey was

performed by ORISE from August 18 through 20, 2003. This Phase 2 survey, although similar

to the Phase 1 survey of 2000, addressed portions of the site not covered during the Phase 1

survey. The Phase 2 survey included all five warehouse components (Areas 23A, 23B, 23C,

23D, and 23E) within the Superbolt Building Complex Number 23. A much larger portion of the

warehouse floor surface area was available for this survey than during the Phase 1 effort. In

addition to conducting radiological measurements at the site, data were gathered to support the

development of a cost estimate associated with the evaluation of the subfloor pits (Adams, 2003).

However, the Phase 2 report does not provide any documentation of a cost estimate being

performed by ESSAP as indicated by the report and documentation of a cost estimate was not

uncovered during the records review by Argonne.

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Results of the Phase 1 and 2 surveys were similar, although a significant amount of

contamination in Areas 23B and 23C, was identified during the Phase 2 survey. Gamma

exposure rates that were measured at a minimum of five locations in each warehouse area ranged

from 6 to 11 μR/hr, which is generally consistent with background exposure rates. The exterior

gamma surface scans did not identify any areas of elevated radiation. The maximum reported

surface total beta activity levels were found in Areas 23B (lower wall) and 23C (floor) at values

of 130,000 and 140,000 dpm/100 cm2, respectively. One surface soil sample that was collected

from beneath a brick floor adjacent to a structural I-beam footer in Area 23B produced

concentrations of 221 pCi/g for U-238 and 9.2 pCi/g for U-235. Ten residue samples produced

maximum concentrations for U-238 and U-235 of 3,600 and 138 pCi/g, respectively.

2.4.6 ORAU Dose Assessment

In addition to the five aforementioned radiological surveys, a dose reconstruction project

was initiated by the Oak Ridge Associated Universities (ORAU) for the National Institute for

Occupational Safety and Health (NIOSH). The ORAU noted that the possibility of enriched and

recycled uranium having been processed by Superior Steel could affect the ratios of the uranium

isotopes present at the site. The ORAU dose assessment stated the possibility that Superior Steel

also rolled recycled uranium (ORAU, 2005). If recycled uranium was processed at the site, this

material could have contained certain transuranic radionuclides including neptunium-237 and

plutonium-239 (ORAU 2005). No previous survey or sampling programs were designed to test

for possible fission-product or transuranic radionuclides.

3.0 SOIL EXPOSURE AND AIR PATHWAYS

3.1 Physical Conditions

The Superior Steel site of Scott Township, PA lies within the Pittsburgh Low Section of

the Appalachian Plateau physiographic province, which is characterized in southwestern

Pennsylvania as upland plateaus dissected by deep or incised stream valleys. The regional

geologic structure is the East Dunkard Basin, which contains Mississippian to Pennsylvanian

(Carboniferous) Formations exhibiting coal resources. Superior Steel likely is underlain by the

Conemaugh and/or the Monogahela Groups, which are comprised of interlayered sandstones,

siltstones, shales and coal seams. The Dunkard Group is located to the south and contains

similar lithology.

The site occupies an alluvial terrace adjacent to Chartiers Creek. Topography varies from

about 900 ft in the eastern residential upland to 760 ft along the bank of Chartiers Creek. The

industrial site is relatively flat lying and locally varies between 780 and 770 ft, and thus about 10

to 20 feet above the normal creek level. The interior of the Bldg. 23 complex is a mix of

concrete and dirt floors, while the exterior of the building is predominantly a mix of concrete,

asphalt, and gravel out to approximately 25 feet. Very little if any exposed soil surrounds the

building.

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The USDA-NRCS STATSGO (State Soil Geographic) data indicate that soils in the

Chartiers Creek valley are predominantly Alleghany soil types normally found on 3- to 8-percent

slopes. The soils vary up to 7 feet deep and are composed of silt to silty clay loams that coarsen

with depth to silty sand and gravelly silt, sand and clay mixtures (homogenous loams). This

vertical texture change is coincident with the alluvial depositional setting in the Chartiers Creek

valley. Deeper site soils will reflect the variably textured point bar and floodplain deposits

common to upland stream systems. Alleghany soils are designated hydrologic group B, soils that

are well drained and permeable; they normally are found on terraces, footslopes, and alluvial

deposits, such as those underlying the SSC site.

3.2 Soil and Air Pathways and Direct Radiation

The 2000 Federal census estimated that Scott Township contains 17,288 people,

including 3,437 children ages 19 and under, within a total land area of 3.86 square miles. The

nearest residential area is located about 100 yards east of the former SSC facilities.

Potential air pathway receptors from residual radioactivity at the former SSC site are to

workers from Superbolt Inc and individuals living and working around the former SSC that must

access the Bldg. 23 complex to store or retrieve product or supplies from this area. Superbolt

Inc. previously leased contaminated areas to other businesses as storage space and limited light

industrial activities; the leasing of Bldg. 23 complex ceased after the ORISE surveys. However,

on August 29, 2006 during a site visit to the former SSC complex, representatives from

Superbolt Inc. indicated that the northern third of Bldg. 23B is leased to a trucking company.

Superbolt representatives indicated the owner of the company used the area occasionally for

performing maintenance on his vehicles. Potential offsite receptors located in the general

vicinity of the site include other manufacturing and office buildings occupying the former SSC

complex. Schools, residential areas and other commercial businesses are found within a mile of

the site.

Of the five radiological surveys completed at the former SSC site, the two ORISE

surveys were the most comprehensive since they assessed each area within the Bldg. 23

complex. Each building area in the Bldg. 23 complex was surveyed using various methods that

included soil and residue sampling, surface scans, and exposure rates. The soil and residue

sampling indicates that radiological contamination is present in the Bldg. 23 complex and salt

bath area above interim screening values found in NUREG-1757. The interim screening values

in NUREG-1757 for surface soils for U-238 and U-235 are 14.0 and 8.0 pCi/g, respectively.

These values represent surficial soil concentrations of individual radionuclides that would

comply with the 25mrem/yr unrestricted release dose limit in 10 CFR 20.1402. Table 1 shows

the historical soil and residue sample results in the various buildings within the Bldg. 23

complex.

Table 2 presents elevated surface scan measurements for beta activity that were

performed within the Bldg. 23 complex during the 2000 and 2003 ORISE surveys. Of the 149

direct measurement locations during the ORISE surveys, 43 exceed the average guideline found

in Engineer Manual 385-1-80, Table 6-4, Surface Radioactivity Values (dpm/100 cm2) for

Superior Steel Corporation 11

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natural uranium, which are 1000 dpm/100 cm2 for removable and 5,000 dpm/100 cm2 for total

average concentration over one square meter .

3.3 Soil Exposure, Air Pathway, and Direct Radiation Conclusions

Data indicate that elevated concentrations of U-235 and U-238 are present at the former

SSC site in concentrations above screening guidelines indicating that the site would not be

suitable for NRC license decommissioning without further evaluation. Elevated activity defined

by the two ORISE surveys (2000 and 2003) in the uranium metal processing area indicate

surface and subsurface contamination exist in areas occupied by the salt bath and the old storage

shed which are both external to the Bldg. 23 complex as depicted in Figure 2.

The residue samples and surface scans taken from various other areas indicate that both

fixed and removable contaminations are present within the Bldg. 23 Complex. Superbolt

representatives have indicated that they now only lease a small area in Bldg. 23B to a small

trucking firm. The removable contamination within areas of the Bldg. 23 complex may pose a

threat, or potential threat, of migration to the environment outside of the complex if site

conditions were to change.

The document search and the results of the ORISE surveys indicate that there is evidence of

AEC related contamination at the site and contamination has migrated to the environment from

inside the Bldg. 23 complex. Further investigation is warranted at the site to evaluate the nature

and extent of AEC contamination from uranium metal processing.

4.0 GROUNDWATER PATHWAY

4.1 Hydrogeologic Setting

The greatest portion of groundwater used in Allegheny County, about 80% to 90%,

comes from valley-fill alluvial aquifers. The remainder comes typically from bedrock aquifers

of the Conemaugh or Allegheny Groups; significant yields also consistently come from the

Morgantown Formation sandstones. The carbonate rocks of the Sewickley Formation are also a

reliable source of groundwater.

The local or site groundwater hydrology is inferred from regional features that include an

upland area to the east and Chartiers Creek along the remainder of the site, which lies within a

meander bend in Chartiers Creek. The floodplain that the site occupies is likely underlain by

alluvial sediments that vary from clayey silt to silty gravel at depth. This depositional setting is

confirmed partly by the STATSGO soil data provided by the USDA (NRCS), which is normal

for such a depositional feature.

Groundwater flow is expected to flow from east to west on the SSC site. The eastern

upland represents a groundwater recharge area that likely creates a radial flow pattern from the

upland towards the creek. The site groundwater flow patterns probably transmit groundwater

from the upland, through the sediments underlying the site, and into the creek. Stage heights in

Superior Steel Corporation 12

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the creek likely affect short-term groundwater levels, although not the final fate of groundwater

flow to the creek. Potential releases of site contaminants to groundwater would eventually

migrate to Chartiers Creek.

4.2 Ground Water Pathways

The residents in this area, including the Borough of Carnegie and the city of Pittsburgh,

receive their drinking water from a municipal water source described further in section 5.0 of

this document. The Allegheny County Health Department has stated that no drinking water

wells are reported (or recorded) to exist within 1 mile of the site (via personal communication).

This does not preclude the existence of unreported wells in the area.

The SSC site owner also stated that no drinking or operations water is derived from on-

site groundwater sources.

4.3 Ground Water Pathway Conclusions

A potential exists for an on-site release of uranium to migrate to groundwater and

discharge to Chartiers Creek. However, this pathway is diminished due to the availability of

municipal drinking water located in the region.

Groundwater at the SSC site has not been sampled for radionuclides and the exposure

pathway remains uncharacterized. A groundwater quality investigation is required to assess

potential doses from groundwater and associated media (e.g., discharges to surface water).

5.0 SURFACE WATER PATHWAY

5.1 Hydrologic Setting

The upland area east of the SSC site is occupied by residential development and St.

Joseph’s Cemetery. Surface water runoff is directed to storm sewers and possibly a small

network of drainage ditches that flow to Chartiers Creek. A USGS gaging station on Chartiers

Creek (#3085500) adjacent to the SSC site actively monitors stage height for a drainage area of

257 square miles. The average discharge of Chartiers Creek at the gage station is 293 cubic feet

per second at a stage elevation of 755.45 feet, which is based on annual average discharge data

from 1920 to 2005. This elevation is 15 to 25 feet below the average site topography and

indicates the site drains to Chartiers Creek; underlying groundwater also likely discharges to the

reach along the site. From the site and nearby gage station, Chartiers Creek flows 8.9 miles into

the Ohio River at a confluence downstream of Pittsburgh.

The topography of the site along the creek has led to localized flooding, which occurred

most recently in September 2004, when the remnants of Hurricane Ivan inundated the Bldg. 23

complex under 4 feet of water.

Superior Steel Corporation 13

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5.2 Surface Water Pathways

Southwestern Pennsylvania drains into the Monongahela, Allegheny, and Ohio Rivers via

a large network of tributaries (up to fifth order streams). The pool of rivers and various streams

is regulated by the US Army Corps of Engineers at intervals along the rivers. The Ohio River

drains into the Mississippi River, which eventually drains into the Gulf of Mexico. Chartiers

Creek bounds the former SSC site on the north, south and west and is a tributary of the Ohio

River.

The Monongahela River is the sole source of drinking water for the Pennsylvania

American Water Company, which provides drinking water to the Town of Carnegie, the City of

Pittsburgh, and other municipalities in the area. The Monongahela River is upstream of where

Chartiers Creek enters the Ohio River. The Pennsylvania American Water Company maintains

treatment facilities on the Monongahela River capable of producing a maximum of 110 million

gallons of water per day. The water supply is distributed for residential, commercial, and

industrial use.

5.3 Surface Water Pathway Conclusion

The presence of surface soil, building, and subsurface contamination may have impacted

site surface water (storm water) management systems. A potential exists for contaminated

sediments to exist in storm water sewer lines and near surface water outfalls into Chartiers

Creek due to the flooding that occurred in 2004 at the site. The flooding that occurred in 2004

may have deposited AEC-related material into storm sewer catch basin and into the sediment of

Chartiers Creek. This potential exposure pathway was not characterized by past surveys and

thus the potential risk remains unquantified.

6.0 COMBINED PATHWAY CONCLUSION

A complete pathways analysis could not be derived from the information at hand. Data

indicate that elevated concentrations of uranium 235 and 238 are present at the SSC site above

interim screening values. Areas of elevated activity exist both inside and outside of the Bldg.

23 complex where AEC operations occurred. In addition, areas within the Bldg. 23 complex

that were not known to have been used for AEC-related work, have radioactive contamination

present as indicated by the ORISE surveys.

Data collected during the ORISE surveys indicate that both surface (0”-6”) and sub-

surface (6”-12”) radiological contamination exist at the site. Subsurface media is impacted in

several areas however, the vertical extent of contamination at the site is not known.

The groundwater pathway remains unquantified and therefore suspect since both surface

and subsurface soil contamination is present. The potential for site contamination to leach to

groundwater is evident in the salt bath area, central pit feature, and soil adjacent to the Building

23 complex. A groundwater investigation should be performed to quantify flow vectors,

potential contaminant concentrations, and migration pathways to Chartiers Creek and associated

receptors.

Superior Steel Corporation 14

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The surface water pathway also remains unquantified but potentially contaminated due to

soil contamination on site. The quantification of potential contamination in this media (surface

water and associated sediment) will determine pathway risks to on-site occupants and potential

receptors (both ecologic and human) in contact with water and sediments in Chartiers Creek.

7.0 SUMMARY AND CONCLUSIONS

The United States Army of Corps of Engineers has reviewed existing available data on

the former Superior Steel Corporation Site. Based on that review, there is evidence of release or

threat of release of radioactive materials related to the Nation’s early atomic energy program.

Migration of AEC-related material has occurred from the Bldg. 23 complex to the surrounding

surface and subsurface soils. There is the potential for waterborne AEC-related material to

migrate from the site, and if future ground water or surface water receptors were identified,

there may be an adverse impact on human health and the environment.

Therefore, in accordance with CERCLA, it is recommended that further investigation be

undertaken within FUSRAP, beginning with a remedial investigation to determine the nature

and extent of AEC-related contamination and the associated risks to human health and the

environment.

Superior Steel Corporation 15

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8.0 REFERENCES

Adams, W.C., 2001, Radiological Scoping Survey of Portions of the Former Superior Steel

Company, Carnegie, Pennsylvania, Final Report, ORISE 01-0740, prepared by Oak Ridge

Institute for Science and Education, Oak Ridge, Tennessee, for U.S. Nuclear Regulatory

Commission, Region 1, May.

Adams, W.C., 2003, Radiological Scoping Survey for Portions of the Superbolt Facility

(Formerly Superior Steel Company), Phase 2, Carnegie, Pennsylvania, Final Report, ORISE 03-

1528, prepared by Oak Ridge Institute for Science and Education, Oak Ridge, Tennessee, for

U.S. Nuclear Regulatory Commission, Region 1, November.

Aerospace Corporation, 1985, Authority Review – The Former Superior Steel Corporation Site –

AEC Contract No. AT(30-1)-1412, letter from Charles D. Young (Environmental Controls and

Analysis Directorate, Government Support Division) to Mr. Arthur Whitman (Division of

Facility and Site Decommissioning Projects, Office of Nuclear Energy, U.S. Department of

Energy) with attachment, September 30.

AHP (Applied Health Physics), 1997a, Field Service Report, report from Todd Mobley,

Technical Services Supervisor, Applied Health Physics, Inc., Bethel Park, Pennsylvania, to Mr.

Rolf Steinbock, Superbolt, Inc., Carnegie, Pennsylvania, June 24.

AHP, 1997b, Field Service Report, report from Todd Mobley, Applied Health Physics, Inc.,

Bethel Park, Pennsylvania, to Mr. Rolf Steinbock, Superbolt, Inc., Carnegie, Pennsylvania,

September 3.

AHP, 1997c, Field Service Report, report from Todd Mobley, Applied Health Physics, Inc.,

Bethel Park, Pennsylvania, to Mr. Rolf Steinbock, Superbolt, Inc., Carnegie, Pennsylvania,

December 2.

Argonne National Lab, 2006, Records Review and Evaluation Report for the Former Superior

Steel Site, Carnegie, Pennsylvania, October 2006.

Myrick, T.E., and C. Clark, 1981, Preliminary Site Survey Report for the Former Superior Steel

Mill at Carnegie, Pennsylvania, prepared by Oak Ridge National Laboratory, Oak Ridge,

Tennessee, for Environmental and Safety Engineering Division, Office of Environmental

Protection, Safety, and Emergency Preparedness, U.S. Department of Energy, April.

NRC (U.S. Nuclear Regulatory Commission), 2006, Superbolt (Formerly Superior Steel).

Available at http://www.nrc.gov/info-finder/decommissioning/complex/superior-steel-formerly-

superbolt-.html. Last revised May 3, 2006.

NUREG –1757, Consolidated NMSS Decommissioning Guidance, U.S. Nuclear Regulatory

Commission, September, 2002

Superior Steel Corporation 16

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ORAU (Oak Ridge Associated Universities), 2005, An Exposure Matrix for Superior Steel,

Carnegie, Pennsylvania, Period of Operation: January 1, 1952 through December 31, 1957,

ORAUT-TKBS-0034, ORAU Team Dose Reconstruction Project for NIOSH, Oak Ridge,

Tennessee, August 9.

Owen, M.W., 2006, letter from Michael W. Owen (Director, Office of Legacy Management,

U.S. Department of Energy) to Don T. Riley (Major General, Director of Civil Works, U.S.

Army Corps of Engineers), February 3.

Whitman, A.J., 1985, letter from Arthur J. Whitman (Division of Facility and Site

Decommissioning Projects, Office of Nuclear Energy, U.S. Department of Energy) to Mr.

Andrew Wallo III (The Aerospace Corporation), October 28.

USEPA (United States Environmental Protection Agency), 1991. Guidance for Performing

Preliminary Assessments Under CERCLA. September 1991.

Superior Steel Corporation 17

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ATTACHMENT A

DOE Eligibility Letter

CECW-LRD

DEPARTMENT OF THE ARMY

u.s.

ARMY CORPS OF ENGINEERS

WASHINGTON,

D.C.

20314-1000

MAR

2 2

2008

MEMORANDUM FOR COMMANDER, GREAT LAKES AND OHIO RIVER DIVISION,

P.O. BOX 1159, CINCINNATI, OH 45201-1159

SUBJECT: Fonnerly Utilized Sites Remedial Action Program Site

the fonner Superior Steel

Company Site in Carnegie, Pennsylvania

Enclosed is a copy

the letter received from the Department

Energy (DOE) regarding the

fonner Superior Steel Company in Carnegie, Pennsylvania. In their letter

3 February 2006,

DOE stated that the site is eligible for inclusion in FUSRAP. In accordance with the

Memorandum

Understanding (MOU) between the U.S.

Anny

Corps

Engineers and DOE, the

Corps is responsible for doing the radiological characterization

the site that is required to

detennine whether contamination exceeds current guidelines and cleanup is warranted.

As stated in their letter, DOE has perforn1ed additional historical research and revisited the

1985 detennination regarding the inclusion

the site in the FUSRAP. The research results

confinn that this site was used for activities that supported the Nation's early atomic energy

program. Additional characterization under Section IILD.2

the MOU is necessary to detennine

the need for cleanup at the site to address the FUSRAP-related contamination

I request you provide a Preliminary Assessment (PA) report and preliminary legal analysis per

Engineer Regulation 200-1-4. This infonnation will

used to detennine

the site will be

designated for cleanup under the FUSRAP.

Mr. Allen Steinbock, Vice President

Superbolt, Inc., is the point

contact at the fonner

Superior Steel Company site and can

reached at (412) 279-1149. Point

contact at the DOE

is Mr. Christopher Clayton at (202) 586-9034.

Please provide a cost estimate and schedule for completion

the P A and preliminary legal

analysis

28 April 2006.

point

contact for this action is Mr. Dale Moeller, Program

Manager, CECW-LRD at (202) 761-4494.

FOR THE COMMANDER:

Encl Major General, USA

Director

Civil Works

FEB.

12.2006

8:55PM

Department

Energy

Washington, DC 20585

Don

Riley,

MGEN,

USA

Director

Civil Works

HQ,

Army Corps

Engineers

441

G St, NW

Washington, D.C. 20314-1000

Dear

General

Riley:

February

2006

NO.

0263

writing

notify

you

that

the

current

owner

the

former Superior

Steel

Company

site

Carnegie, Pennsylvania,

(Superbolt,

Inc.)

has,

with the

knowledge

and

support

the

Commonwealth

Pennsylvania

and

regional

representatives

the

Nuclear

Regulatory Commission (NRC),

requested

assistance

arranging for

cleanup

of.residual

radioactive material

the

site

under

the

Fonnerly

Utilized Sites Remedial Action

Program (FUSRAP).

Although copies

the contract have

not

beet1

found, historical

records

indicate

that

June 27, 1952; was the effective date of the

ABC

contract with the fonner Superior

Steel

Company.

The scope

work

included

the

rolling

and

machining offlat

plates

uranium

mtt:al

into

strips

used

the

cores

fuel

elements.

The contract

was

terminated

on or about September

30,

1957.

The

facilities

owned

and

operated

Superior Steel

during

the

mid-1950s

are

located in

the

area

currently

occupied

the Carnegie

Industrial

Park

on Superior

and

Hammond

Streets,

Scott

Townshipt Pennsylvania. The

large

steel structure that housed

the

uranium

processing

areas

is currently owned

Superbolt, Incorporated.

The

report

of the preliminary site survey

conducted

in 1980

personnel

the Oak Ridge National

Laboratory

(ORNL) is available on the Department

Energy (Legacy Management)

web

page

h:ttp:llcsd.gio.doe.gov. The

document

number

PA.034. A more current

description

the

site

(about

acres

bounded

the

north,

west and south by

ChatUers

Creek

and

the

east

Superior Street) and

the

. building

which

the

contract

work

was

perfonned is included in

the

May

2001

Radiological Scoping Survey report

prepared

for

the

NRC,

Region

by the

Oak

Ridge

Institute for Science and

Education

(ORISE)

(copy

attached),

This

site

-was

previously

considered

for

cleanup

under

FUSRAP.

The

preliminary

radiological

survey

conducted at

the

site

the

Oak

Ridge

National

Labox:atory

1980

found

evidence

residual

uranium

contamination in several areas

the

remaining

structures

the site.

However,

due

site

conditions

limiting access

suspected

areas

contamiliation and other factors, consideration for cleanup under FUSRAP

did

not

proceed beyond the prelinlinary

survey_

More detailed characterizations

the site have

since been conducted.

The

scoping

survey

conducted

2001

ORISE served to

confirm

the continued presence

residual

uranium

contamination and provide

the

information necessary

develop a

conlprehensive

characterization plan

for

the

site.

Mr.

Allen Steinbock,

the

Vice President

Superbolt, Inc. can be reached at (412) 279-

1149.

Pri'IIed

with

IOV

Ink

lecycled

paper

FEB.

12.2006

8:55PM

NO.

0263

addition

the work

performed

for

the

ABC,

Superior

Steel Corporation

was

licensed

1956

to"

... receive possession of

and/or

title

unlimited

quantities

thorium

n1etal

for

rolling and cutting."

The

purpose

the

license

was

to receive source material

(thorium

metal)

from

another

commercial

licensee

and

process

the

metal

into

the

desired

shape.

Section III.D.I.

the

Memorandum

Understanding

(MOU)

between

the

DOE

and

the

Army

Corps

Engineers regarding

the

program

administration and execution

the

FUSRAP

provides that

DOE:

Shall

pedorm historical

research

and

provide'

a FUSRAP eligibility detennination,

with

historical references3

whether

a site

was

used

for

activities

which

supported

the

Nation's early

,atom.ic

energy

program;

Shall provide the

Army

Corps

Engineers

with

the

determination,

a description

the

type

processes

involved

in the historical activities

the site,

the

geographic boundaries

those

,activities

(as

reflected

doc'UIUentation

available

DOE))

and the potential

radioactive

and/or chemical contaminants at

the

site;

and,

Shall maintain records

detennination

eligibility

and

other

files~

documents

and

records associated

witQ.

the

site.

accordance

with the

MOU

and

the

request

from

Superhol1,

the

DOE

has

conducted

additional historical research

and

revisited

the

1985

determination regarding

the

inclusion

the

site

in FUSRAP. The results

the

research confinn

that

this site

was

used

for

-activities

that supported the Nation's

early

atomic

energy program and is

eligible

for

inclusion

FUSRAP. Any residual radioactive contamination from

commercial

operations involving thorium

metal

not

considered

eligible for FUSRAP

cleanup.

Additional radiological characterization

under

Section

III.D.2

the

MOU

necessary

detemune the need for cleanup at

the

site

address

the FUSRAP-related

contamination.

Additional relevant historical

documents

will

furnished under separate

cover.

appreciate the Corps'

assistance

and

will

continue

work cooperatively

with

your

staffin

carrying

out the

terms

the

MOU.

Please

contact Christopher

Clayton

staff

(202)

586-9034

you

need

further

information

in this matter.

Enclosure

cc:

Shaton

Wagner,

CECW-IP

HQ,

Anny

Corps

Engineers

441

GSr.,NW

Washington,

D.C.

20314-JOOO

Sincerely,

Michael

Owen

Director

OffiCe

Legacy Management

Superior Steel Corporation 18

USACE

FIGURES

Figure 1

Superior Steel Site Location

Residences

are located

on Superior St.

Superior Steel Corporation

USACE

FOR YOUR EXCLUSIVE REVIEW AND COMMENT; NOT FOR PUBLIC RELEASE

Superior Steel Corporation

USACE

FOR YOUR EXCLUSIVE REVIEW AND COMMENT; NOT FOR PUBLIC RELEASE

Superior Steel Corporation

USACE

FOR YOUR EXCLUSIVE REVIEW AND COMMENT; NOT FOR PUBLIC RELEASE

Superior Steel Corporation

USACE

FOR YOUR EXCLUSIVE REVIEW AND COMMENT; NOT FOR PUBLIC RELEASE

Figure 2

Layout of Building 23 Complex Areas

And

Locations of Process Machinery

Structure removed

in 1997 by site

owner.

Superior Steel Corporation

USACE

FOR YOUR EXCLUSIVE REVIEW AND COMMENT; NOT FOR PUBLIC RELEASE

Superior Steel Corporation

USACE

FOR YOUR EXCLUSIVE REVIEW AND COMMENT; NOT FOR PUBLIC RELEASE

Superior Steel Corporation

USACE

FOR YOUR EXCLUSIVE REVIEW AND COMMENT; NOT FOR PUBLIC RELEASE

Superior Steel Corporation

USACE

FOR YOUR EXCLUSIVE REVIEW AND COMMENT; NOT FOR PUBLIC RELEASE

Figure 3

Process Layout

Structure removed

in 1997 by site

owner.

23A

23E

23D

Superior Steel Corporation

USACE

FOR YOUR EXCLUSIVE REVIEW AND COMMENT; NOT FOR PUBLIC RELEASE

Superior Steel Corporation

USACE

FOR YOUR EXCLUSIVE REVIEW AND COMMENT; NOT FOR PUBLIC RELEASE

Superior Steel Corporation

USACE

FOR YOUR EXCLUSIVE REVIEW AND COMMENT; NOT FOR PUBLIC RELEASE

Superior Steel Corporation

USACE

FOR YOUR EXCLUSIVE REVIEW AND COMMENT; NOT FOR PUBLIC RELEASE

Superior Steel Corporation 22

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TABLES

Superior Steel Corporation 23

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Table 1

Historical Elevated Soil/Residue Samples

Radionuclide Concentration (pCi/g)Building

Location

(Bolded type indicates

exterior sample locations)

Sample

Type U-235

Surface Soil Screening

Value from NUREG-1757

is 8 pCi/g

U-238

Surface Soil Screening

Value from NUREG-

1757 is 14 pCi/g

Salt Bath (1)1 North of 23A at 0” – 6” depth 529 7180

Salt Bath (1) 1 North of 23A at 6” – 12” depth 18.2 250

Salt Bath (2) 1 North of 23A at 0” – 6” depth 128.8 2013

Salt Bath (2) 1 North of 23A at 6” – 12” depth 3.8 53.8

Salt Bath (pit 1) 1 North of 23A 128.8 530

23B2Residue/dust from I-Beam 15.9 380

23B2Brick with residue from floor 27.6 590

23B2Residue from floor surface 15.6 323

23B2Residue from floor surface by

railroad track

79.7 2,100

23C2Residue from floor surface 138 3,600

23C2Residue from floor surface 25.2 573

23D1Residue from concrete block 5.7 102

23D1Residue from lower wall 12.9 279

23D1Residue from I-Beam 3.1 15.4

23D1Exterior (old storage shed area)

concrete rubble

1,620 23,400

23D1Residue from crane beam 4.4 94

23D1Concrete Paint/ Dust 29.7 538

23D1Concrete Paint/ Dust 4.4 48

23D1Soil sample 3.5 72.4

23D1Soil sample 2.3 42.8

23D (exterior SW corner) 1 Soil Sample 1.1 22.1

23D (exterior SW corner) 1 Soil Sample 3.5 74.4

23D (old storage shed) 1 Soil Sample (0”-6”) 26.7 628

23D (old storage shed) 1 Soil Sample (6”-12”) 2.7 58.5

23D (old storage shed) 1 Soil Sample 19.2 413

23D2Residue from upper surface 5.6 158

23E2Residue/dust from I-Beam 12 345

23E2Residue/dust from I-Beam 8.7 181

23E2Residue/dust from I-Beam 9.7 239

1ORISE 21 May 2001

2ORISE 18 September 2003

Superior Steel Corporation 24

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Table 2

Surface Activity Levels Building 23 Complex

LocationaSurfaceb Total Beta Activityc

(dpm/100 cm2)

23A F 7,400

23A LW 16,000

23A F 8,000

23B US 16,000

23B F 6,900

23B LW 27,000

23B F 17,000

23B LW 7,000

23B F 63,000

23B LW 5,500

23B LW 100,000

23B F 130,000

23B LW 7,500

23B LW 8,200

23B F 22,000

23B F 13,000

23B F 31,000

23C F 140,000

23C F 86,000

23C F 74,000

23C F 18,000

23C F 44,000

23C F 8,400

23C F 33,000

23D US 11,000

23D US 15,000

23D F 7,300

23D F 6,600

23D F 44,000

23D LW 6,900

23D F 6,500

23E US 6,800

23E US 6,100

23E US 7,200

23E US 5,500

23E F 6,900

23E F 9,200

23E F 6,100

23E LW 12,000

23E F 13,000

aData taken from ORISE 18 September 2003 survey

bF = floor, LW = lower wall, and US = upper surface

cMeasurements were all assumed to be from beta particles only due to the dust/residue on the measured surfaces

Superior Steel Corporation 25

USACE

Table 3

Uranium Isotopic Concentrations in Soil Samples

Uranium Isotopic Concentration (pCi/g)

U-234 U-235 U-238

150 + 13 6.4 + 0.9 149 + 13

625 + 52 28.6 + 3.3 637 + 53

34.9 + 3 1.8 + 0.3 33.1 + 2.9

11.6 + 1 0.6 + 0.1 11.9 + 1

100.5 + 8.8 5.7 + 0.9 97.4 + 8.6

* Uncertainties represent the 95% confidence levels based on total propagated uncertainty.

Superior Steel Pa 2007 02

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