1977-06-10 – NRC – Latty Avenue – IE Special Investigation Report No. 76-01 – Full Version from MDNR

1977-06-10-nrc-latty-avenue-ie-special-investigation-report-no-76-01-full-version-from-mdnr

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”’
Mn. Carolyn A.ahfozod
Director, Hi!!lsouri Departttel’lt
of Natur4l F~sources
P.o. Boz 1363
. Jeffenon .City, HO 65101
Deu Mrs. Aahfo1Xl2
JUN 10 197T
th1a refera to a epeeial inveatia&tion conducted by this office
to obtain infor.cation pertaining to the disposal of natural
ut>aoium on residues in a. St. Louia Cowty landfill area by
‘the Cotter Corporat:iou during 1973. ‘l’hilil also refers to the
diaeus•ions held witb t!essr.s. K. V. Miller and G. MacUutt of
the State of P4.aeouri l!ureau of Rca.iolog:!.cal Health 1n
St. Louis on Juna 6 and 7. 1977 t at which tir.lc a c:opy of our
:l.nvestination report waa furnished to them. Althoush there
were uo items of none=plianca w-ith NRC requint:tents f ouud
during this investigation, the lillC balieves that a more detaile ‘ .
Company and continued until about November 1970.’ During the August
to November period, all of the residues were shipped to Canon City with
the exception of approximately 10,000 tons of Colorado raffinate and
8700 tons of leached barium sulfate. There was no further activity
at the Latty Avenue site until mid-1973.
During an inspection conducted in April 1974, a Region III inspector
was informed that during the period July-Dctober 1973, the remaining
Colorado raffinate was shipped to Canon City without drying and the
leached barium sulfate along with 38,000 to 39,000 tons of soil had
been disposed of in a landfill area in St. Louis County. The leached
barium sulfate contained from 0.05% to 0.1% uranium as u3oR. Twelve (12)
to eighteen (18) inches of the topsoil was stripped from tne Latty Avenue
site and disposed of with the leached barium sulfate.
Visit to Cotter Corporation, Lakewood, Colorado
On June 22, 1976, the following information was obtained during a visit
to the Cotter Corporation, Lakewood, Colorado offices. Mr. David P.
Marcott, Executive Vice President of Cotter Corporation, stated that
all of the source material once stockpiled at the Latty Avenue site had
been shipped by rail to its facility in Canon City, Colorado, except the
approximate 8700 tons of leached barium sulfate. The material had very
low concentrations of uranium, from 0.05% to 0.1%, and it was considered
commercially impractical to further process this material to remove
./the uranium. He indicated that it would be necessary to process the
material with several hundred pounds of hydrochloric acid to leach a
pound of uranium from each ton of the barium sulfate. !f the uranium
could be leached out using water the licensee would certainly have
processed the material rather than disposing of it. He indicated that
for this reason he was confident that the uranium remaining in the
\ leached barium sulfate now located in a landfill would not leach out
\ ~into the groundwater. He said that the average uranium content of ore
currently being processed by the mining industry was 0.16% which is
greater than that disposed of in the St. Louis area. He indicated that
some ore being processed by Cotter Corporation contains 0.65% uranium.
He indicated that in his opinion the uranium contained in the leached
barium sulfate did not constitute any threat to the environment
wherever it is now located.
Marcott further advised that he visited the site on more than one
occasion in 1973. He indicated that on one occasion Mr. Robert Davis
of B&K Construction Company drove him around the area and pointed out
to him the landfill area where the material would be dumped. He said
he could not recall the name or location of the area. It was his
recollection that the landfill area had a large deep pit. It was on
this basis that he had expressed the opinion that the material was
probably buried under 100 feet of soil and garbage. He indicated that
he also visited the Latty Avenue site on another occasion and personally
saw the trucks removing the dirt from the premises.
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WLLFOIA4312- 001 – 0018545
Marcott stated that B&K supplied weight sheets along with the invoices
submitted for payment for disposing of the barium sulfate and dirt
from the Latty Avenue site. These invoices also included charges for
the Colorado raffinate shipped by rail to Canon City during the same
period of time.
Mr. Duane A. Dughman, Vice President-Finance of Cotter Corporat’ ion,
provided copies of 11 invoices for the period July to October 1973.
These invoices showed a total of 48,544.70 tons of material were trucked
to a disposal site which is not identified on the invoices. The invoices
also showed that 10,763.41 tons of material were shipped by ra.il during
the same period.
Dughman stated that he had reviewed all related records in Cotter’s files
and none of them identified the landfill area to which B&K Construction
had taken the material. Dughman stated that the only papers relating
to the Latty Avenue site not contained in the master files in the
Lakewood, Colorado offices were the weight sheets that had accompanied
B&K’s invoices. He indicated that these had been retained at the Canon
City facility. He made an inquiry by telephone of personnel at the
Canon City facility concerning the wei~ht sheets and was advised that
they couldn’t be located. It was indicated that Mr. Warren Goff, who was
away and not scheduled to return for several days, was the only one
who could locate them.
Copies of the 11 invoices were obtained and copies of them, with the
cost entries deleted, are attached to this report as Exhibit c.
Visit to West Lake Landfill, Bridgeton, Missouri
On June 23, 1976, the following information was obtained from Mr. Vernon
Fehr, Superintendent of Plant No. 1 West Lake Landfill.
Fehr indicated that he recalled that about three years ago, B&K
Construction Company had dumped what he understood to be clean fill in
an area adjacent to the office building. He indicated that he had seen
the material being dumped and it looked like ordinary dirt to him.
Since clean landfill is useful as cover, there is no charge for dumping
it and no records are maintained of its receipt. It was his recollection
that the dumping of the material did not involve any formal arrangements.
The truck drivers just came to the site and he told them where to dump
it. He stated that he could identify the specific location where the
material was dumped and estimated that it was three feet down. While
he recalled that a large quantity of material was dumped, he was somewhat
doubtful that it totalled 39,000 tons.
Fehr advised that in 1974 the Missouri Department of Natural Resources
advised West Lake to discontinue dumping in two areas on the site,
one of those being the area where the B&K material was located. He
indicated that this area was full anyway. He went on to say that the
State required them to sink \.;ells around the area so that samples of
the groundwater could be obtained. He indicated that the State
– 1 –
r1 WLLFOIA4312- 001 – 0018546
obtained and analyzed groundwater samples from the wells and did not
report any problems regarding their findings. He said the wells are
still there.
Telephone Contacts with Ryckman, Edgerley, Tomlinson & Associates!
St. Louis Missouri

On June 23, 1976, telephone contacts were made with Dr. E. Edgerley
and with Mr. Phillip K. Feeney of Ryckman, Edgerley, Tomlinson &
Associates, an environmental engineering firm that provided consultant
services to Cotter Corporation on health physics and site decontamination.
Dr. Edgerley stated that while he had visited the Cotter Corporation
Latty Avenue site when the residues were being dryed and shipped to
Canon City, Colorado, he had no personal knowledge concerning ·the
disposal of the material remaining onsite after these operations were
discontinued.
Mr. Feeney stated that he was aware that the topsoil was stripped from
the Latty Avenue site and trucked to a landfill but he did not know which
one. He indicated that arrangements regarding the disposal operations
were made directly between Cotter Corporation’and B&K Construction
Company. Feeney stated that he visited the site to perform a termination
survey after being informed that the disposal operations were completed.
During the first survey he made he found one small spot above 0.6 mR/hr.
He instructed B&K to remove some dirt from this area which he indicated
would be a truckload or less. Subsequently, he returned to the site and
found less than 0.1 mR/hr. By letter dated May, 1974, the results of
Feeney’s survey were furnished to Cotter Corporation. A copy of this
letter with ~ts attachments appears as Exhibit D in this report.
Visit to B&K Construction Company, St. Ann, .Missouri
On June 24, 1976, Mr. Robert S. Davis, Vice President, B&K Construction
Company, was interviewed.· Davis stated that the amount
of material shown on the invoices submitted to Cotter Corporation was
disposed of by trucking to the West Lake Landfill during the period
July 16 to October 9, 1973 with the exception of 5,000 tons. He indicated
that this 5,000 tons represented topsoil stockpiled in one corner of
the Latty Avenue site. He had removed it and then returned it to the
site after disposal operations were completed. This topsoil along with
other topsoil was used to dress the site. He felt that he should be
paid for handling the stockpiled topsoil and that the 5,000 tons was
included in the amounts on the invoices sent to Cotter Corporation.
Davis stated that while there was no charge for dumping the material
at West Lake, he had arranged to have the individual operating the scales
there to record the weights of each truck on sheets of paper. He indicated
he was required by Cotter Corporation to submit these weight sheets with
the invoices. Davis provided copies of the weight sheets which bear
the heading “B&K Dirt Hauling” and the date. The following information is
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n WLLFOIA4312- 001 – 0018547
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recorded: truck number, gross, tare, and net weights. A spot check
was made of the totals of the net weights shown on the sheets as well
as the totals of the net weights for a billing period with the weights
on the covering invoice. No discrepancies were found. There were a
total of 104 weight sheets associated with these invoices. The total
weight of material trucked to the disposal area shown on the invoices
was 48,544.70 tons. Subtracting the 5,000 tons of topsoil referred to
above, the amount of material trucked to the disposal area was 43,544.70
tons. ‘The invoices also show a total of 10,763.41 tons of material were
shipped by rail to ~anon City.
Although the above invoices and weight sheets did not indicate the
disposal area to which the material was taken, Davis stated that it
was taken to the West Lake Landfill. He offered for review a job card
record relating to the Latty Avenue site and several entries were noted
for the period July 16, 1973 to October 10, 1973 which indicated
residue was taken to West Lake from Cotter, Latty Avenue.
Davis also stated that in addition to using his own trucks, he arranged
for much of the hauling to be done by other trucking firms. He made
available for review from his records, bills from these firms. Weekly
billing statements, with drivers time tickets attached, covering the
period August 3, 1973 to October 12, 1973 were noted from Walker
Trucking Service, Ferguson, Missouri. These billing statements contain
the notation “Latty Avenue to West Lake.u Billings were also reviewed
which had been received from the following: Bruce Barnes Truck Service,
St. Louis; Vic Koepke Excavating and Grading Company, Bridgeton; and
H. Reeder Hauling, Inc., St. Louis. On at least some of these billings,
there are entries showing that material was hauled from “Latty Avenue”
or “Cotter” to West Lake.
It is concluded that the material in question is now buried under
about three feet of clean soil at the West Lake Landfill. While little
significance was attached to the actual location of the disposed
material at the time of the 1974 inspection, the licensee was notified,
by letter dated November 1, 1974, that the disposal did not appear
to be within the intent of the Commission’s 10 CFR 40 regulations
(Exhibit E) concerning alteration of source material to obtain a mixture
no longer subject to licensing.
Visit to Latty Avenue, Hazelwood, Missouri Site and West Lake Landfill,
Bridgeton, Missouri Site
On August 11, 1976, two Inspection and Enforcement Region III inspectors
visited the Latty Avenue site and West Lake Landfill site for the purposes
of performing radiation surveys and collecting environmental samples.
The Region III inspectors were accompanied by Mr. Stephen Nagle to the
Latty Avenue site and Mr. Clarence Stein to the West Lake Landfill site.
Messrs. Nagle and Stein represented the State of Missouri Division of
Environmental Quality, Department of Natural Resources.
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WLLFOIA4312- 001 – 0018548
..
The results of the August 11, 1976 surveys of the Latty Avenue site and
the West Lake Landfill site with a narrative and reference material are
attached to this report as Attachment A.
Results of the analyses of the environmental samples taken on August 11,
1976 from the Latty Avenue site and West Lake Landfill site are attached to
this report as Attachment B.
Measurements performed at the West Lake Landfill and analyses of samples
from the area have been reviewed. The following hazard analysis is based
on the measurements and analyses and on information derived from personnel
of the former licensee.
Direct Radiation – West Lake Landfill
Beta-gamma measurements made at three feet from the surface indicate two
general areas where readings above background were noted. These measurements
indicated 0.06 mrad/hr maximum. The measurements at contact
indicated 0.8 mrad/hr maximum, and about 0.1 mrad/hr average. Thus, for
continuous exposure the maximum gonadal or whole body dose would be:
0.06 mrad/hr X 8.76 x 103 hrs
500 millirems/year. year 500 millirads/year or approximately
However, the area has been closed for dumping by Missouri DNR and is
essentially unoccupied.
Calculated Atmospheric Concentrations of Rn-222 at West Lake Landfill
West Lake Landfill area sample analytical results do not indicate the
presence of significant natural uranium activity. These surface samples,
however, would not be expected to be representative of material which
is reportedly covered by overburden with a thickness of approximately
one meter.
According to information provided by the licensee, the covered material
consists of approximately 7 tons of natural uranium in about 8,700 tons
of barium sulfate and about 39,000 tons of soil. Thus, an approximate
natural uranium weight percentage of the mixture woul~ 7be 0.015 percent.
With a natural uranium specific activity of 6.77 x 10 Ci/g, th~ 10 specific activitl4of the mixture would be approximately 1.0 x 10
Ci/g or 1.0 x 10 uCi/g. Analysis of two surface samples from the Latty
Avenue site (source of the covered material) ind!~ated natural
uranium concentrations of approximately 1.0 x 10 uCi/g, which supports
this estimate of average mixture concentration. !~e Ra-226 analysis
showed an average concentration of about 1.0 x 10 uCi/g for the two
samples.
– 10 –
n WLLFOIA4312- 001 – 0018549
Calculations have been performed to estimate radon-222 emanation from
the ground,_1ue to buried material with an average Ra-226 concentration
of 1.0 x 10 uCi/g below a depth of 100 em. These calculations indicate
a total release of approximately 0.1 uCi/sec of radon-222 from the
ground due to the covered tailings mixture. It should be noted that
the assumed depth of burial yields a reduction of about a factor of
three below what emanations would exist, assuming no cover.
Additional calculations were performed using the ‘·’virtual point source”
method for determining average air concentration of radon-222 above the
covered material. The area was estimated to be approximately square,
lith a dimension of forty meters. This calculation yielded an approximate
0 atmose2eric d!spersion coefficient in the center of the area of
f.7 x 10 sec/m •
Applying this coefficient to the release rate of 0.1 uCi/sec_~ields jn
average increase in background air concentration of 1.7 x 10 uCi/m
directly over the covered tailings, which is about one-half of the
10 CFR 20 unrestricted area concentration limits. This Rn-222 contribution
in air, due to the buried materials, would be indistinguishable
from backcround within a few hundred meters from the landfill. Based
on the conservatism of assumptions, this atmospheric concentration of
Rn-222 is considered an upper limit. Calculations are appended to this
report as Attachment c.
Other Pathwa;ts
Pathways other than direct exposure and inhalation of radon-222 and progeny
do not appear to be significant. No likely means of an ingestion
pathway were identified, and inhalation due to fumigative dusting can
be discounted since the material is covered and not subject to b~coming
airborne. An evaluation of the potential for groundwater contamination
could not be made in the absence of information concerning the hydrogeologic
character of the local area. Three shallow (about 20 feet)
wells in the area were all found to be dry at the time the IE:III
inspectors visited the site, precluding collection and analysis of
groundwater samples. As noted above, barium sulfate and u3o8 are known
to be insoluble in water.
Future Development
It is noted that the radium 226 concentration of materials
presumed buried at the West Lake Landfill approximates that found
in tailings materials used for leveling, aggregate and backfill
under or around the foundations of dwellings in certain western
Colorado communities. Some of these Colorado dwellings experience
indoor radon 222 concentrations capable of yielding exposures
approaching those implied in the occupational limits of 10 CFR 20.
Differences in the physical and chemical natures of the West Lake
Landfill and the western Colorado tailings, however, suggest a
lower radon release fraction for materials of the type buried
at the land fill. Recognizing the potential for radon buildup in
– 11 –
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/'”
dwellings and the uncertainties concerning certain parameters needed
to estimate that potential at the West Lake Landfill, a complete
environmental impact assessment is necessary to accurately evaluate
the hazard potential for this pathway.
Comparison with 10 CFR 20 Criteria
Finally, it should be noted that a licensee may bury up to about two
tons of natural uranium per year (in twelve increments) within criteria
contained in 10 CFR 20 concerning depth (4 feet) and spacing (6 foot
spacing between locations). Thus, in four years, eight tons could be
disposed of in forty-eight one-sixth ton batches buried in a grid with
six foot centers: Such a grid would comprise an area significantly
smaller than that found in this case, while containing about the same
quant~ty of disposed uranium.
0 0 0 0 0 0 0
0 0 0 0 0 0 0
0 0 .o 06 ot 0 0 “‘ 0 0 06 ot 0 0 0 36 ft “‘ 11 m
0 0 0 0 0 0 0
0 0 0 0 0 0 0
0 0 0 0 0 0 0
“M·–~~ y 36 ft :’~ 11m …. “:c..;. —-·-.. ~
Conclusion
Seven tons of. uranium could be disposed of by burial in accordance with·
10 CFR 20.304 in an area significantly smaller than that now existing
at the West Lake Landfill. Based on our estimates of maximum potential
exposure conditions by various pathways, it is concluded that the
material now present at the West Lake Landfill does not represent a
radiological hazard by any pathway yet identified. Based on studies of
the use of uranium tailings for backfill and leveling under and around
residence foundations in Colorado, it is estimated that increased indoor
radon and radon progeny concentrations could be experienced in structures
built directly in or on the disposed tailings. An environmental
impact analysis is required for an accurate estimate of the hazard
potential for this pathway.
Attachments:
l •. Attachments A, B, C and D
2. Exhibits A-E
3. References 1-4
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WLLFOIA4312- 001 – 0018551
·.
ATTACHMENT A
During a survey performed by this office on August 11, 1976, to
determine the effectiveness of Cotter Corporation’s decommissioning
of their Hazelwood, Missouri (Latty Avenue) site, a difference in
the radiation readings supplied by Cotter and those found by this
office was noted.
On May 10, 1974, Cotter reported exposure rates which ranged from
0.01 to 0.4 mR/hr measured at three feet above grade (type of instrument
unknown). (Reference 1) These values were the basis for
·termination of the license by the Directorate of Licensing.
(Reference 2) The Region III August 11, 1976 survey, made at the
same distance, yielded readings ranging from 0.3 to 0.8 mrad/hr
beta-gamma. (Reference 3) Additionally, a survey at one centimeter
revealed t~o areas reading 1.2 and 1.8 mrad/hr beta-gamma. The
instrument used by IE:III inspectors in performing these measurements
was an Eberl~ne E-SOOB with an end-window Model HP-190 Hand Probe
(1.4-2 mg/cm ).
The presently acceptable limit for release of ground areas, as implied
in the “Decontamination Guide” (Reference 4) is 0.4 mrad/hr, total,
or 0.2 mrad/hr, average, with a maximum of 1.0 mrad/hr, all of which are to be measured at 1 em with a probe of not more than 7 mg/cm 2
of total adsorber. Thus, the NRC Region III survey of August 11, 1976 ·
showed radiation levels at the Latty Avenue site exceeding the acceptable
release limits, while the survey performed by Cotter Corporation
showed levels within the guidelines. Both surveys indicate a low, nonhazardous
radiation level. The difference in results might be
artributable to differences in instruments and procedures used. The
August 11, 1976 surveys were the first independent examination by NRC
of radiation levels at the Latty Avenue site.
..
n WLLFOIA4312- 001 – 0018552
:2: r
r
11
0
~ .w…..
N
0
0
0
.0.. …
OJ
01
01 w
….
..
~


Sample No.
L-1
·L-2
L-3
L-4
W-1
W-2
.. Note: 1)
2)
3)
4)
5)
ATTACHMENT B
ENVIRONMENTAL SAMPLE
Analytical Results by HSL
Results (uCi/g)
Sample Description
Soil
Soil
Vegetation
Wet Sediment From
Cold Water Creek
Soil
Soil

L-1 through L-4 collected at Latty Avenue Site
W-1, W-2 collected at West Lake Landfill
Natural Uranium
1.2 + 0.1 E-4
7.5 + 0.1 E-5
2.6 + 0.2 E-5
5.3 + 0.4 E-6
5 + 2 E-7
5.3 + 0.4 E-6
L-3 vegetation dried, analyzed dry, reported as wet weight
L-4 dried prior to analysis
A systemic error of + 20% should be assigned to Ra-226 analysis
due to uncertainty of the equilibrium between Rn-222 and Rn-226.
An 80% equilibrium ratio was assumed.
Ra-226
1.4 + 0.03 E-3
5.14 + 0.14 E-4
t.~
·.
ATTACHMENT C
RI\-222 Emanation Calcula’tions
1. Rn-222 at the Spoils/Cover Interface
Total release • (area) ~ (source flux) ~
• (1600 m ) x DC (A/(DS))
. 0
Assume:
Kraner. et al, the Natural
Radiation Environment, 1964
D • 1.5 x 10-2 cm2/sec 1 x 10 -1 == 10% “emanation power”
. 3
C • (1.0 nCi/g)(1.6 g/cm )(1 x
0 . 3 3
• 0.16 nCi/cm = 160 pCi/cm
(fraction escaping solid soil gas)
Tanner, The Natural Radiation
Environment, 1964
A • 2.099 x 10-6 sec-1
s – 0.25 0.25 • soil “void fraction”
‘Total release= (1.9 x 107)(1.5’x 10-2)(160)(2.099 x 10-6/(1.5 x 10-2 /0.25))~
• (3.84 X 107)(3.5 X 1~-5 )~
Total release = 2.3 x 105 pCi/sec over 1.6 x 107 cm2
area release= 1.44 x 10-2 pCi/cm2• sec
2. Rn-222 at the Surface of the Cover
c2 • c1 exp (-Z(A/D)~
Assume:
cl
D
>.
. -2 . 2 = 1.44 x 10 pCi/cm •
• 1.5 x 10- 2 em 2 /sec
• 2.099 x 10 -6 sec -1
Z • 100 em
sec
Tanner, The Natural Radiation
Environment, 1964
C2 a (1,44 X 10-2) exp (-100 (2,099 X 10-6/1.5 X 10-2 )~)
• (1.44 x 10-2) exp (-1.18)
• (1,44 X 10-2) (0.31)
C2 • 4.4 X 10-3 pCi/cm2• sec
Entire area: (4.4 x 10-3) (1.6 x 107) = 7.0 x 104 pCi/sec
Therefore, the total emanation rate is about 70 nCi/sec, or about
0.1 pCi/sec.
.n ‘
WLLFOIA4312- 001 – 0018554
… 2
3. Atmospheric Dispersion Coefficient
•,
X/Q • 1/rra y a z u
a and a are calculated using the “virtual point source” method
d~scribea in Workbook of Atmospheric Dispersion Estimates, as
follows:
a. for a square area with 40m sides, a yo • S/4.3 • 40/4.3 • 9.3m
b. in the area, ay o = aY • 9.3m
c. at 20m (center of area from side), stability class E, and
ground-level release, o z = 1m
d. assume annual avg. windspeed is 2 m/sec
X/Q • 1/(3.14)(1)(9.3)(2) = 1.7 x 10-2. sec/m3
4. Concentration in Air
Concentration= (0.1 uCi/sec)(l.7 x 10-2 sec/m3) • 1.7 x 10-3 uCi/m3
&……. .•
n WLLFOIA4312- 001 – 0018555
. ·. ….
..
INVESTIGA’f10:i FOR URANIUH/TllORIUH
.
COTTER CORPORATION. I..ATTY AVENUE SITF., ST. LOUIS, HISSOUlU
OCTOnER 20, 1976
‘Pursuant to the ongoing investigation of possible uranium/thorium
contamination at the Latty Avenue site, Hes::a :{. J. A. Pagliaro and
G. T. Gibson performed a site inspection on October 20, 1976. The
pu~pose of this inspection was to identify the property owner from
·county tax records, to survey the property w:i.th bi:~tn-gamma and
alpha survey instrrnncntaticn, and to obtain selected soil and
·vegetation samples for laboratory analyses,
I
The records rev:te-v1ed at the St. Louis County Buildine, 41 South
Central, St. Louis, Missouri, were the current county property tax
rolls. County personnel. stated the tax records t!Xmnined were
dated as of July 1976. The record indicated the following:
Address: 9200 J..atty Avenue
Owner:
Size:
Cotrunerd.al Discotmt Corporstion
55 East Honroc Street
Chicago, Illinois 60602
3.5 acres
‘ ………….
Telephone communication t-lith IE: III was performed to ascertain
whether thta prpp,!rt)’ had since been transferred. Additional
information \-1&3 received t·lhich indicated Commercial Discour.t
Corporation had tnmsferred m·mership of the prop~rty in Augunt 1976
to the Bayless Company~ 175 Outer Road Uest • Valley Park, Hissouri.
..
A site investigntion was then performed and samples were obtoincci.
Figure 1 indicates the relative podtion of vadous buildings,
landmarkc, and locntions of collected samples. The area in Fiuure 1
encompassing the abandoned garage, abandoned warehouse building~
and the abandoned and boarded-up burned bu:i.lding wns estimated to be
approximately three (3) acres. The entire area, in~luding t.:hw
warehouse arc::1 anJ plowed field, y,•as estimated t:o be in e>:cess ~
surface” chunks ranged in size from 4 x 4 x l inches to small flakes.
The material was somctvhat fibcrous in texture. The “yellow surface11
material had an apparent beta-gamma flux of ·10 mR/hr at contact.
Approximately 1. 5 pounds of the “yellot.J surfnce11 was collected for
~·laboratory analysis. Several holes were dug to a depth of 15 inches
but no subsurface yellow material was excavated. ·
I
Selected soybeans were collected from the plotved field, \1as surveyed with beta-gamma and alpha
instruments. The floor of the wnrehousc was composed of dirt and
broken concrete. Several elevated readings above background activity
were recorded. The highest apparent location was in the.center of
the “mrehouse, beside a suppc>rt column. Readings of up to 0. 8 mli/hr
beta-gamma and 30,000 DPH alpha \>Jere observed. A 11 ~arehouse dirt”
sample, consisting of approximately 2 pounds of topsoil was obtained
for ~~boratory analysis.
Preliminary radiological analyses were performed at IE:III using
beta-garmna, alpha, and gam.111a-spec troscopy instrumcnta tion. The
samples Here then fon:arded to ERDA: Health Services Labo~:atory (HSL),
Idaho Falls, Idaho.
The results of the IE:III analyses showed no detectable activity
in either soybean smnplc. The 11 yello\<.' sul·face" sample shm·1ed · 10 tnR/hr beta-gamma and 4,000 Dl'H alpha at contact with a fm.J grams of materinl. Gcnuna scanning \vith an unshielded Nai crystal indicatcct the presence of unmium isotopes but not thorium and thor.ium daught<~rs. Tho "warehouse dirt11 sample showed 0.3 tnR/hr bcta-gnmma and 26,000 DPH alpha at contact \dth a sample of about 250 g. Ganuna scanning tvith Nai indicated both uranium and thorium and their decay chain produds to ba prcwent • ,v ... I WLLFOIA4312- 001 - 0018557 ... ' ·~· - 3- 'I .. The results of alpha spectroscopic analyses of the two soil samples by • HSL are present~d in T~blc !.below. HSL analyses of the two soybean samples showed only small quantities of naturally-occurring K-40. TABLE I Alpha Spectroscopic Radionuclide Concentration (uCi/u) Th-230 3.61 ++ 0.05 E-02 Th-227 I 4.4 + 0.2 E-Olt U-238 6.64 + 0.06 -g,...o4 U-234 6.52 + 0.06 E-04 U-235 3.09 + 0,07 E-05 Ra-226 5.2 - 0.1 E-0'• Warehouse Dirt U-238 0.3 ++ 0.1 U-231• 0.3 + 0.1 U-235. 0.3 - 0.1 E-02 Ye11D\>~ Haterial
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WLLFOIA4312- 001 – 0018558
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Lct.•Ll4Y>S: .:tr. Keppler:
June 2, 1976
In articles published May 30 and June 1 (copies enclosed) St. Louis
Post-Dispatch reporter }iargaret H. Freivogel presented evidence that
some seven tons of uranium were dumped in 1973 at the \·lest Lake Landfill
in St. Louis County by an Atomic Energy Commission subcontractor
removing radioactive Haste material from a site in Hazeh>lood, Hissouri.
The area tvas closed as an industrial and sanitary landfill by this
Department in 1974 (a new sanitary landfill in an adjacent area protected
from ground{>later contact now operates under DNR permit). The
closed area where the dumping allegedly occurred may be in direct
contact with groundwater. It has no monitoring wells to permit
evaluation of groundwater contamination.
In your letter to me of February 19, 1976 you stated that “a revie\>l by
the then AEC showed there was no significant health or environmental
hazard associated with the burial”. The letter to Cotter Corporation
from John G. Davis you enclosed stated, “It is our understanding from
your contractor that the material was then deposited under about
100 feet of refuse and earth at St. Louis County sanitary landfill
No. 1.” The investigation by the Post-Dispatch iudicates that AEC. did
not know the correct location of the dumping, the local geology, nor
the actual concentration of uranium dumped. The depth cited must
also be incorrect since no landfills in the St. Louis area contain
100 feet of fill. l must therefore question the validity of the ABC
“review” of the burial operation.
I respectfully request that in view of the concerns of this Department
and the people of the St. Louis area, that the Nuclear Regulatory
Commission takes steps to:
1. Provide me with all documents which might assist me in verifying
the Post-Dispatch report, and in establishing the exact amount
and chemical form of radioactive materials allegedly dumpeJ at
West Lake.
Exhibit A
1 of 4
L
WLLFOIA4312- 001 – 0018560
• \
.Mr. Keppler
Page 2
June 2, 1976
2. Require the Energy Research and Development Administration,
as successor to AEC’s source material operations, to
3.
a) Include the West Lake Landfill in the areas it has selected
for intensive aerial and ground level radiation monitoring.
b) Locate the uranium precisely within the landfill, both as
to position and depth.
e) Install appropriate groundwater monitoring wells and implement
a monitoring program to determine the extent, if any, of
groundwater contamination.
d)
a)
b)
Recommend actions to be taken to protect landfill workers
and the public from any potential hazards associated with
this material.
Advise me on who would be liable in the event that cleanup
costs are involved.
Ascertain whether federal laws or regulations were violated
by either the Atomic Energy Commission.or its subcontractor
in the disposal of source material at an unlicensed site.
In a related matter, I was disappointed to learn that you do not maintain
records of radioactive waste burials carr{ed out by licensees under
authority of Section 20.304 of Title 10 CFR. I hereby respectfully
request that your office obtain such records from all Hissouri licensees
who have made such burials and make these records available to me.
/~-K.;;~Ce:;..-n~e,…th…….,M””l. .K~,-< arch fh. ~._..---Director K.MK:JE:jhb ee: Robert J. Koke. EPA Region VII Enclosure Division of Environmental Quality Exhibit A 2 of 4 J. .... ~- •• rWLLFOIA4312- 001 - 0018561 :2: r r 11 0 ); ~ .w.... N I 0 0 0 .0.. .. OJ 01 0) N - 1 ~ ~./- _J w~ ~ 0 lLJJ ~ ~ ~dJ£~TC~~ ""._. ~ .. .....,. 1 ,_......,...... , .. ......_~ ...... • .,..,,..\k ...... !-"""" t ~;;.;&x. ( :, .... .~..·,. ,... ......... !i•»• (:.,< ,.,..... e.,., ..... ~. ·--"-·~ ,.,_ • T. u ••• o, .. ;...; ''" -,.. -....... ~:::.7';.._ t ...._.. _..._ t ...,. .~ ... -:. '. \ ......... -... ,h .. --. '!.,:, ·t:.-; t''~ --.~- .1 /' .. .. - .- • f • : . .. t\ Y. ~lAY :~o. I tho.! in
s clc:.rly
ln::ccur!
l t\ucle.
aid this
!c px~d
~e:;u!ato·
· Ato::lic
tra~~ or
In ac!ditlon to being v:ron;:: about the
vo!!.!::::! or th: ‘”:::!::~, f~c!~:::t recc:;o:ltcd at ••st. Loul!l County LondCUl
No. 1 0:1 Old Crldgc no:td.” No such
p!:l~c cxls:s.
Tl:c U t: K vice prcs!!!cnt, D:l\’ls,
cc::!irr.’:c:! lh::.t til:! m:l:~tia! !’;~c! r:o::~ 😮
th~ West L:::.b~ L:::.::d!ill on St. Cl’::::.:-l:s
Roc!: r.oad. St. Louis Cocr.ty ta!l~ml
r:o. 1 is on D::r:;ctt <:!!'!~ t.die noo.C:s, rr.o:~ tt:n !.::::- r:!~!!5 :'..'·~·~:'. Th~ \'lest L.::::~ L:::-:::::~1 \i::!!: e!~:::d tcr:-:~'lr~ri!y in 1'7·! fer irz:prc-.·.:::::::::s bcc~u:c st::tc c::ic!=:!s fC'..:..--:1 t!:::: c~r:~!:: pc!!~::1r.ts ,,·ere lc::!:~::~ fro::-: it in:o the s:.:rrm:::d!::z r.c:::! p:::!:1 ::c!!. t!o tcs~ ror r::~:e::.cth~;!j· \"~·:::: r.::::!.:J !:~:::~=~ r!!ic:~!;; were unaware tl'::lt an}' radio::u:tive m::terials wera in tl:.:! !::::~nil. Bcror~ tlae imprcv~u:c:::.s '\\·~r~ ~~!. II would h:sve ta:er. "irresp::::tlh!e .. to put an)' h:u2rdous \;·.u:! at Wes: Ldke, s:tld J os.:ph Eigner, who tt.:r.s the ~~iSSOt::'i h::.:i::ri!o:;,.; ~·~z!e r:o:;:-::.rn. The pr::!i!e:::l ::< \'.'es: La}:e t::.lj' b·;e been comy~u:.~~~ b:: cs:::~ t~: r~~i::;~ ... ti\·e m:ltcri::!l as a ::-..!: S~!!.
Tt:! t::iu::-: s~!~.1:~ a:.! c:!’:!: -;.:s:c
~:-:-C:.:::s c::;:::~!~i· ~r~:-! s:.::z:! z: I…l~·
b~::. Fie~:!. La:e:. s:;=e c! t:”:c: ,;;e:-i
c~-.-e:! to 3 st:~ a: ~:;;J :.a::r R:.:~ ..
Ha:~:-:.·~. in p;-e;.:::-:;.:;.-:: ::.r r~::x:~
S…””e Ct~:::.:’.:G. F:;~ f
~yin~
~r i~s
!d.
•rt~nt
r:-:t’re
ho.t is
sarr:p!cs c! tl:c tmc::b::!:; t:::::::;; sz:;t to
the lanc:m. hut he ~’.:l:r.awl:::c;;:::d that
tt:cy, teo, eol!ld h:wo t:::::t i:l::cc1.::::::::!.
Fe:!~=-::.! ~uthor!!i~s m:11c no f~C:;:t~r..d …
ent r::c:::surcmc~ts cf the strength of
tr.:lt~r!::l ~nd nor~:!!y net in a case
!il:e tl~is, a s~::!:c!:~:n for the t~uclc:tr
Re:.;t:btory Cor::r::is$::m said. Rc!:,·l::3 0:1
Cotter’s rccorrl.;, a federal inspector
ccncludcd that the eoncen: ratio;~ of
uran:um in the matcri:.t! bdn:; C!.::::lpcd
·was .o~:n per cc!1!–::el! t:::ow the .05
per cent limit set in the rcgu!aticns.
the l!aze!~-:ocd site for rac!!ation ar.d
found it c!c:::’l.
AEC im:cs:i;:ato:s did fin~ !ac!t w:th
one :xs;:;~ct of the was:c disr:o~:.!!. The
agency rcp:ir:::.!:-:~::-d Co:ter Co:p. in a
letter Co: di!c:wly watched by lw; co::•;;.:r.y, llle C~C;Ot,.Ci’r\,”i:; \’:,’A!:ii: storoCjO crccs. t:.cp inoicctes where ‘~
cngln1\.crini~ 111r~~~;-~~ :1 \1vc ‘,~.E~~·.~~-~c,·t.o! the barium sul!cf~ wcs cricir:;il·,· stored, tha ~ite en 92w lc:::/ .J .of
4 ~ th{‘ t 1rcf’t’ ac u'”l ‘ .. “‘””‘ \.. …. …. \\..’li ~… .iiJ ~ .. ‘·t..
,..,,,·,.,;.1 n r .. f.: m,;.,-.. .J 1•: t:n· l<:n:dfill. Rood. ond where 1t v:os moved. the West lcke lcncfill ot St.:...;.~~-:::-_ · t :2: r r "'Tl 0 ~ .w..... N 0 0 0 0... ... OJ 01 ~-··-, ,. ' " .. 1{jj ·lo A o _((l:E}~ J·1D~~J,l~\a E1L~~r~®ll-ofr~IT~: CCfu~~n~§ -tfllillsrl1F~ra1t; E:.· =':!.~:!G.\nET w. fREl\'OGEL • I l.egblature w enact a radiation protection ..~.~t tno~ ur ·.,a,re .md ,.. ..1 : tn i~7; t•> !h”” : … :
Cf :.!le P::s:-O:Sjlatcb Staff f.. ·1·7 ‘-
So :.~nt: ::l!t..~J!!dy rr.1mitvrs radicactive mal~·
rJal:> Ill ~.!., ;.,;t::l :u::l ;!;;: ~:a :c is U:Jjiri!parcd to
h~’!’:C:!e :~cc:c!c::t.~! r~!cases of radJatinn, two
sta:e :.!~:=:a!$ !J::il!lar ‘»’1:h t!le :;itu.~uon ~;ay.
‘T::i: c!:.::;:;!::z :.! SC’.’I7!r:d tMusar.d tens of low.
1!:’~·~ 1 r “‘:!:::;.:.:<~~·r: wa~tr: at tbe \':est Lake ta::~!;ll ::~ s:. l.;;u;:; Co:.mt:;. dt<.clcS<:d S::nday in tiH Pr;s:-!):£paah - l.i only one or :if:\'eral m.:.:le:.r-:~!..o: .. d pr1.l;,!·~:n->, sau.l Kenneth M.
Y…I:C!’: ;::-;:! :.!.l:.’IO !\…d1f!.
};.;;.:.~ .; ..:;:.,.:::vr -.: .:r.1;ironmer::al GU:!Iity for
1!:1: :>::m· :’)e;::trt:r.em uf Natural Rt·sources;
!’to;!;:; ::> :::e c!c;:;.:a:men:·s ~irectcr of planning
::.:::! ;;ell.::: de·;e:<:p::ler.r~ T::~re ;s ::o .:~·1der.c:e t!':at the West take C::.::::;:;:~g ~z..:,ec J !-.!':.:::h hlza:d, bur it ap?are: a:\· ::c::-.~:.:s.::d !ec!e:ll aut!:.orities wllc were s:.:;;)oscd ~o te #:~e;::r=o~ tr;.t~k of t!u! materi:ll. F l;~e ::,..; .. ::::;:. re<. d~·:~e.
·Tm .;.:..:: uf :te A:om:c Energy Co::::nis$JtiO·s
n::..::>t c.:::;-:<:::o .::::!:cs." s.Jid O:!v:d P. :\ta::-cou. e:.:ttc:::·.:<: ·;:c" :-:,·~:c!t:r.! of Cott!.'r Corp . whicn ·h.,.! ;: -r•::-;t-c :~c ·x;;,re rr. a ~•·::t;,u::;ed.
..:
·”‘
.. Ninety-nine per cent of the time they
(f..,Jeral authorities) don’t know wb:u·s gomg on
tven ‘o.l!ht•n th~y havr: someone !\landing there
… As a citizen and as a member of !hls
.ndu:.lry. I’d like tu see them do .J beucr F·:S:•
Maitvll sa1d.
f\vd1!f Jl:.d Karch said they were dl!lturhc:d by
the W .:~t luke incident because It was, In their
opulion, inchcati>e o( serioUS gaps lhal e«iSI in
&he munitorina uf low-lt:vcl waste.
rh~ federal Nuclear ltcuut:uury t:umrrilsslon,
·,\llich replaced ll;e rww cuf:.tncl Atomic E;~ergy
1 Commt:>sioa is too s~orthan~c-d 10 tn-.:cst:~a:e
:c•lrr.prchcnsi\·ely, tbe oHidal.s said. State offtcials
ha\·e no authority to ftll in for the federal
agcmcy, they said.
Thcj’listcd sever~! ;>ro!.:!cms, ir.cluding:
(1) ln:to•.vcr plants situated near
enough to J’.lJsscuri w cause injury tn the sta~e
a::1 fr<1m Union Ell'ctr!c Comp:my·~ Callaway ·Cou:o:y plam ::ow u:-:der •:onstr~wtton. 0} lnadequ:t!c al!ent10o w tilt' transpnrtal!on of r;,dinartive mawri:tl~ throur!h the sratc. TriSt. ll.: ~totor Co .• the largest mmsporter of nucle:u m ba~::d in
Joplm. >tn HQ’Nevcr, mnst •>f Its c::rgo dP~S not
~J<;S lhn>o)!~ ‘.1!sso:Jri. a study by the Dt•p:lrt·
nwn; ‘•I ~; .;\.nl R~sr,urces (oun:J.
!(::rch ‘”ttl :\odrff [ailt’d t(l cunvi!!r~ th::o
dorms th~: !;txt :;ession. II would have t:rr.pu;~.- :-rtt!Jitd at St. Ch .• r:..-:. Ruck R~,;.:;c J:;-! ;,J
ered :;rate ufhcials to m•mitur morl! t>UI!flin:lv Ru:~c!
\\’.ISh.• dl~pusal and lranspor~auon. The ;,;!Jt~ ln. 1· .• 1 . 8″·'” ·•t1·, .. r , ···tt’··’ • . . ••..
-u (f ICi.t ~ls pt. an til orge cnactm~.:nr of r”. . e lll’gt!>’. l!· l•~m ‘.•. f, ‘tt..· ·• ‘ “··” ‘h” ‘ J’· ·r .• ,.\ .u• .:,t .. ,..~~ ”’~. ····.•· • . . …. u ._,,i. • ..,. hu s:u lt..’\:t utJ.O :1\.t\’V
t:an ~g;un next :.t-:.smn. . Rl.’l’.’lll;l ur. iht· ;::.;.lrrn: :::~·m~~·, .11\ ·, “1 he f.-dt•ral a~ent·l~li just arcn’l mannc·~ •., · · ·’·
~~o~ttt·!~ tn~pt· …. :or .:cr.~l •. h.!t·.! t:t~t. the ·•..s:Ht:
&.· …. ;; ~;L::\·~ ~’ ah ~utl t.1 r::..lu..:”· tb u..!:l·-·~:•
do a tliorucgh and t·ompr … hcnsiw Jnb, .. ~oc.ilU
saul. ”Tht-y’re forced to !>rl priuri\it’S un \\bl .
they lll”~Pt·t:l. Tlwy ~tan With Mry :!0 y•:ar~.”
:\ fctlt-ral .:tomic salety official saia t:e
thmtght th£’ mcnitorlng program was corr.pret:
en~in· enough. · ·
Con:-~qut·1;tl~, Ill.: u;.,;>.:n· r·:- i’c;:••rl 11..
,t:rrur ttfl tl!l’ :-!r.·r.,.:tl:. \ ~·!· .. !’::t- .1:0:..! lu(“‘!” :to
W .. i~tf·. O,! .. p!!e ih’l..~ l:!C.~:·· .. :e\!cr..l! ..lO.! :
u!fH::at~ :;..::.! lt11: :no.k~l;l. r;.:.,J no !:e
~:..z:ml
S.lt·::•: ch:d .\1!::-~ .J
wnrrtt’d abcut ih·: ‘.0…1:>1~ ~:.::: .. : ,;.;:~: <.!< 51:':1 . F~r:n.o: ne~!~ t"•th.t:rtbtJ. ~.rd. t~~ $Hte.:- t;:~ll;:;t:e!:.:;l
!!H.· h!·. .• .. ~l!·\·er \\:~ … ~.: m.:tt:r:::! tJ …t feJ
ct>;·1s.t: :m~a ::1 Shdf;dd, :n .
All.·rt l-a!t! :h<.· m:t!t!'r: .. !l. 'J:tgtn;.~_r,ng f r€''":lrch pr:;,..,.
v.. J;o; \t”‘r\ ”~;\ 1:1 ~·\:t!!a:!~!: ·:::·’.: ~:::C .. t’ :;’J “”;.
~tl”,:t·:·~-:d !’ly f·/~.!t•:’ :~ !’* .. “~.!…:!~:: 1;.;,
.. ,,.s d1~l!lfbing th:H WI! might ‘h:w~: got
incnrn·ct tnformation (about the ·west Llk~
dis;>osa!).” ~aid James Allen, chief -of the fuel ·
bclltt\’ and material s:tfE-ty branch at th-e
:\ud(•;ir Rt•gu!awry Commission’s rt>gwn~l uffa
·\· 111 f;!en Ell•:n, I!L “Rut whcr. thl’fl··~ :1~
!\t.”.dth ~ta;urJ tn•:oh·t•tl m a situatto:l, stnct bt:! K .• rrh ~;!!<:: ~·: w,:, .!.-· .. :: •. ..: rt .• : ::i:::·: mnnnunng or it W!Hold be takmg Pl'Ople ;r.~ay F:t:'TI· 1::!! nu: !Jn:l ;b ~ ·~.:~::::; :>~:l …. :oJ t~
from mun· 1m;wnan1 ht•a!th lS!>t:e~.” bur: a I w·t~ •nr:t·:! :!’~ ” .:< -. ::;. ,::1,..1 .:I •. • Alkn ..,ald he was nnl <'tmcerned ab()Ut th:: h·Jt"r.!: dho:.t:~ r~l:t"d ~"' ~;..,v::-.: .. :: !·" agcnry bcmg du;wd. Th<' We;;t Lake t·pisode ~a;. i::,!••.tu t1f mO.:··tl:·~d' r.; ·:-\·:·· . .:. ··:··~- ·t "' ·l an l""l:tlt·Ubmlll••d ~::!~r mvu:ees tok (vile: !-‘.;:~, :. i’• , :,·!’•·: ·,~: .. : ~ · :-: :· ··~·. =.• .:: < C<•rp •!• 1.• :!'~ t!:.H tf !;ad m•·\'t"\1 r.•:.u!y !0. J~ ·.\·J~ "':•": ···~~·r~h ·.,r :n· .... ,. Exhibit A 4 of 4 I • UNIT£0 STATES NUCLEAR REGULATOHY COMMISSI"' . .J REGION Ill '7U ROOSI:Vt:L T AOI\0 OLEN ELL VN, ILLINOIS tO I 37 JUN 1 7 1976 Mr~ Kenneth M. Karch Director, Division of Environmental Quality Missouri Department of Natural Resources License No. SUB-1022 P. 0. Box 1368 Jefferson City, Missouri Dear Mr. Karch: 65101 This is in response to your letter dated June 2, 1976, requesting additional in£ormation and follow-up action relative to the burial of some seven tons of natural uranium in a St. Louis County land£111 in 1973. The information published in the St. Louis Post-Dispatch on May 30 and June 1, 1976, which was enclosed with your letter of June 2, 1976, is new to this Office and, as you pointed out, conflicts with the information obtained by our inspectors in 1974. Based on this apparent discrepancy, the NRC plans to initiate a full investigation into this matter during the week beginning June 20, 1976. The findings from this investigation, which w211 be made available to you, will determine the need for further NRC action. At the conclusion of the investigation, all documents relative to this burial will be provided to your Office .. With respect to your June 2, 1976 letter, I would like to clarify one apparent misconception at this time. The Cotter Corporation, which was responsible for this burial, was an AEC licensee --- not an AEC subcontractor. Consequently, the ~nergy Research and Development Administration has no responsibility with regard to this material. As a former licensee, the NRC will look to Cotter Corporation to correct any safety or environmental related problems identified through our investigation. Regarding your other request that this office obtain from materials licensees in the State of ~tlssouri records of low level radioactive waste burials under 10 CFR 20.304, I must reiterate that there is no NRC regulation that requires reporting waste burials under 20.304. Therefore, there is no Exhibit B 1 of 2 r 1 WLLFOIA4312- 001 - 0018564 . . . •. Mr. Kenneth M. Karch JUN 1 7 1976 basis for such a requeot to the licensees. If you believe that the NRC's current regulations concerning auch burials are inadequate, you may petition tho NRC for consideration of a chtinge of the regulations. l'hia rulcmnl~ing petition should be submitted under the provisions of 10 CFR 2.802. a copy of which is enclosed • U you have any questions concerning the above • please let me know. Enc.looure: 10 CFR 2,.802 cc w/o encl, w/ltr dtd 6/2/76! R. J. CokeEPA l'..e.g:t.on VII Sincerely yours, JQmeB G. Keppler Regional Director , .. M., Y. l<"reivogel, St. Louis Post-Dispatch D. P. Marcott, Cotter Corporation bee w/o e.ncl, w/ltr dtd 6/2/76: :J. G. Davis, Deputy Director ·D. Thompson, IE:HQ ·L. Rouse, NMSS S. Schwartz, SLR ·J. Fouchard, PA Central Files IE Mail and File Unit PDR NSIC .. . ' . ·: Exhibit B 2 of 2 i JJ,... WLLFOIA4312- 001 - 0018565 •. ---·---.. -.::~ -:-...:: l•tuho••' ·• ·• .• ,NVOJCt ... HArrison 7-5666 r L .. . . ' .. ____ , ___ ----.--1 Cotter Corporation · ··. =: ~ .. • · :/ • •. -:··· ·.: >·
• DliVlWAYS
P.O. Box 751 : · – …. · · · … )
Cannon City, Color:ado ‘81212 .’ ~·
‘;;:-·:~:;~~~ ·..,.,··; ! .. ~~ … :…, __
JOBSITE: Latty Avenue, St Louis County
Material trucked to disposal site
Material shipped by railroad
• nuns
4981.85 tons @$
2341.75 tons @$
• SUUIIVISION$
• fACtOU’ HOOU
• tUKING LOU
THIS INVOICE IS DUE AND PAYABLE WITHIN 10 DAYS AS PER AGREEMENT.
Exhibit C
1 of 11
N~ 10B5~
[
········.- Y”f’OI’~ .# •• 1–:,. …….
• I I •’ “‘•)’Ji .. \
. . . . • \; \”1. ..#·.~~.1’~’-“”~
-… •• ,. ··- ~ fl

WLLFOIA4312- 001 – 0018566
…. ,. … .,., . INVOICE S-.~’!.i>-

HArrison 7·5566 …. t (f ·-·
r
L
\ t· (· ‘ ( f •
• OllVtWAYS
• lftUtS
• SVJOIVISION$
• fACton noo•s
o ,AilKING lOT$
8/10/73
JOBSITE: Latty Avenue, St. Louis County
Material trucked to disposal site Aug. 1st thru Aug. 9th -8373.75 tons
@$.
Material shipped by railroad Aug. 1st. thru Aug. 9th- 846.70 t.nn~
@S
8373.75 tons @$.02 .(scale charge)
r ___ ,_.—·-·—–~•··-·–·–··-·—— •• -~
( THIS lNVOIOE DUE AND PAYABLE WITHIN TEN { 1~2 -~!~—–II j:?
~– . -n- .Jif”
. .;!../ t )-
Exhibit C
2 of 11
r~
WLLFOIA4312- 001 – 0018567
r
L

…. – ··–·-
… ·t .,.,
f ( I f INVOICE (
JV}G 21 ·l· .c.. :I :~,:1t
.4000 7·5666 ( t •••• (· t
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B. &. K. :Con ~.: -~- G · .. u.. any, Inc.
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fjs!r. :.:e~~ V_ , I • OliVfWA’U Cotter Corporation
P.O. Box 7.51
Canon City, Cplorado
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JOBSITE: Latty Avenue – St. Louis County
August 10 through August 16:
6,304.10 tons hauled to disposal area by truck @S
lJ86. 95 tons shipped by rail @ S
6,304.10 tons ® S scale charge
THIS INVOICZ DUE Al~u PAYABLS WITHIN TEN (10) days.
• nuns
• SVlOIVISION$
• fACTO~Y HOOU
• I’AII