1980-09-25 – MDNR – West Lake Landfill – Source of Contamination in Area 2 is unknown at this time

i1 f^- MEMORANDUM * ^*wt SEP 2 5 1980 SOLID Date: September 25, 1980 To: Robert J. Schreiber. through... View Document


1997 – EPA – West Lake Landfill – Conflicting information on who chose West Lake Landfill for illegal disposal of uranium residues

Site Background
West Lake Landfill (the “Site”), Operable Unit No. 1, involves a remedial
investigation/feasibility study (“RI/FS”) being performed by Cotter Corporation (N.S.L.),
Laidlaw Waste Systems (Bridgeton), Inc., Rock Road Industries, Inc. and the U.S. Department of
In 1966, the Atomic Energy Commission (“AEC”) sold 8,700 tons ofleached barium
sulfate, together with other radioactive residues, to Continental Mining and Milling Company
(“Continental Mining”). The radioactive residues were generated as by-products of uranium
processing performed by the AEC’s contractor. These processing residues were stored at the
AEC’s St. Louis Airport Storage Site (“SLAPSS”). Continental Mining moved the radioactive
residues to its facility at 9200 Latty Avenue in Hazelwood, Missouri. Eventually, Cotter
purchased the radioactive residues and shipped all but the 8, 700 tons of leached barium sulfate to
its processing facility in Colorado.
In 1973 approximately 8, 700 tons of radioactively contaminated leached barium sulfate
residues were mixed with approximately 39,000 tons of soil, and the entire amount was disposed
of in two areas of the Site. This material resulted from decontamination efforts undertaken by
Cotter at 9200 Latty A venue, St. Louis, Missouri, where the residues had been stored. Studies
have indicated that these two areas of the landfill are contaminated with uranium-238, uranium-
235, thorium-230 and radium-226. In addition to the radioactive materials in the landfill,
groundwater at the Site is also contaminated with radioactive materials as well as other
hazardous substances.
In 1993 EPA entered into an Administrative Order on Consent (“AOC”) for the
performance of an RI/FS at the Site. As indicated above, Cotter Corporation (N.S.L.), Laidlaw
Waste Systems (Bridgeton), Inc., Rock Road Industries, Inc. and the U.S. Department of Energy
were signatories to this AOC.
Allocation Support
To date the four respondents to the AOC have shared the cost of work equally. While
this allocation has worked for the RI/FS phase of the work, the upcoming remedial
design/remedial investigation (“RD/RA”) will be substantially more costly, and some of the
parties may have difficulty paying a 25% share. The RI/FS is still underway, so no Record of
Decision (“ROD”) has been issued and it is not expected that a ROD will be issued before this
allocation process is complete.
Despite the absence of projected remedial costs, both the PRPs and DOE are willing to
proceed with an allocation effort. In particular, DOE seeks a greater degree of certainty in its
budget planning process, and along with the PRPs may see allocation as an opportunity to adopt
more equitable basis for its liability than the current per capita scheme.
On December 5, 1996, a meeting of the St. Louis Site Task Force meeting was held in St.
Louis, Missouri, which was attended, inter alia, by DOE Assistant Secretary Thomas Grumbley,
EPA Region VII’s Administrator, as well as various other representatives of DOE, EPA, the
State of Missouri, the City and County of St. Louis and staffers from interested Congressional
offices in the state and affected district.
At this meeting DOE Assistant Secretary Grumbley announced that with regard to West
Lake Landfill OU-1, EPA would “allocate the responsibility at the site as best as it can over the
next six months or so, so that they can tell us what percentage of the responsibility that [DOE]
needs to take … . “(Italics added)
As any allocation of responsibility that EPA may prepare, such as an non-binding
allocation of responsibility, may expose EPA to charges of favoritism as DOE is a sister federal
entity. Discussions were held among the four identified potentially responsible parties (“PRPs”)
regarding how best to conduct an allocation. It was agreed that using a third-party neutral
allocator would best serve the interests of the parties and satisfy EPA’ s desire to maintain
Additionally, the private party PRPs, Cotter Corporation (N.S.L.), Laidlaw Waste
Systems (Bridgeton), Inc. and Rock Road Industries, Inc. have requested that in any allocation
performed the allocator give consideration and possibly allocate some responsibility to an
“orphan.” The orphan is B&K Construction Company, which acted as the transporter of the
radioactive materials for Cotter Corporation. It has been alleged that B&K actually chose the
Site for disposal of the wastes, although there appears to be some conflicting information on this.
Therefore, In order to accomplish the allocation, EPA would envision starting as soon as
practicable in order to meet the six-month deadline mentioned above, that is, six months from the
Task Force meeting, or May 5, 1997. While that may be ambitious, EPA still envisions that the
parties would be substantially involved in the process or nearly complete in their efforts by that
The process would involve allocation, with the four PRPs, plus EPA as a party to
represent the “orphan” share mentioned above. An initial convening meeting is expected, with
several additional one-day meetings with all parties in attendance to follow until resolution.
Appropriate shares for costs may include consideration of PRP ability to pay issues, as
driven by a range of estimated costs for various likely, but as yet not selected, remedial
alternatives. Additional costs or liabilities to throw into the mix may include credit for past
contributions under the per capita allocation scheme, EPA’s “orphan” share contribution in the
form of forgiveness of oversight costs, or other mechanisms or sources that may come forward as
the allocation proceeds. EPA would expect that the convening phase of the allocation would
resolve may of these issues to further clarify what the parties expect from the process.
Scope of Work
A. Preliminary Work
1. The contractor shall select an allocator professional to act as convener and allocator for
this process in consultation with the Project Officer (PO) and Delivery Order Project
Officer (DOPO).
2. The allocator professional shall meet with the EPA PO and DOPO and members of
EPA’s team to discuss substantive and procedural issues and define potentially involved
interests and parties. At this meeting EPA representatives will provide more detailed
information with regard to the goals and outcomes expected of the process, list of
potential parties to be included in the process and a list of issues to be addressed through
the process.
3. The contractor shall submit a workplan to EPA in accordance with the requirements of
this contract.
4. The contractor shall be responsible for oversight of deliverables on this delivery order
and shall be responsible for transmission of monthly reports and invoices as required by
the contract.
B. Convening Activities
1. In consultation with the EPA DOPO, the contractor shall identify and contact the affected
parties to discuss the goals and purpose of the proposed allocation process, as well as the
technical or substantive issues involved in the allocation process.
The contractor shall contact parties identified by the EPA DOPO as “key parties” first. If
no barriers to an allocation process are identified, the contractor shall proceed to contact
all parties.
If initial contacts with the key parties reveal that an allocation process is not feasible, the
contractor shall notify the EPA PO and DOPO, explain the difficulties (lack of interest,
unequivocal opposition of a key party, disagreement about the definition of the problem,
wrong forum or process, etc.) and await EPA’s decision on whether to proceed with the
allocation process.
2. The contractor shall provide oral reports weekly to the DOPO on the general progress of
the convening effort.
3. The contractor shall provide one copy of the draft convening report to the EPA Project
Officer and five copies to the DOPO. The report will:
a. Summarize the results of convening contacts including such things as:
( 1) what parties were contacted during the period; and
(2) identification and a discussion of those issues which the parties agree will
be considered as part of the allocation process, and well as those issues
which the parties choose not to have addressed in the allocation process.
b. A discussion of the chances of a successful allocation process and the goals and
purpose of the process from the viewpoints of the parties affected;
c. Recommendation of potential additional parties that should also participate in the
consultative process.
d. If an allocation process appears to be feasible, the report shall include a design for
the process including such things as:
( 1) the structure and type of meetings between/among the allocator
professional and affected parties;
(2) the expected number, length, location and frequency of meetings;
(3) the research, data or information necessary prior to, or during the process;
( 4) the estimated budget for the process as designed and proposed by the
contractor; and
(5) whether an orientation session is recommended prior to the first meeting.
e. If a consultative process is not recommended, the contractor may suggest other
processes that could accomplish some of EPA’ s goals.
The PO and DOPO will review the draft convening report and provide comments and
revisions as necessary. The contractor will prepare the final report incorporating the PO’s
and DOPO’s comments and revisions.
The contractor shall distribute the final report to the PO (2 copies), the DOPO (5 copies)
and to each of the parties interviewed for the report.
4. If EPA decides to proceed with the allocation process, the contractor shall assist it in
contacting potential parties to obtain commitments to participate in the allocation process.
5. As a part of the convening effort, the contractor may arrange for and facilitate an initial
organizational meeting of the parties to discuss the form of the process and the parties to
be involved, to get commitments to go forward from each of the parties, discuss the
issues involved, and/or the ground rules for the process.
C. Allocation
This phase will implement the design of the allocation process as accepted by the EPA
DOPO and PO based upon the final convening report recommendations.
1. The contractor shall propose an initial draft of operational ground rules. At the initial
meetings, the contractor shall assist the group in further developing and refining the
ground rules or operating procedures of process.
2. The contractor shall provide a draft agenda to the PO and DOPO for each meeting. Upon
receipt and incorporation of the PO’s and DOPO’s comments, the contractor shall
distribute the final agenda to the PO, DOPO and participants in the allocation process.
3. The contractor shall facilitate all plenary, subcommittee and workgroup sessions. As
facilitator the contractor shall assist participants in articulating their interests, identifying
areas of agreement, and developing consensus solutions to the problems that divide them.
As facilitator, s/he shall keep the parties talking, listening, and moving – as much as
possible – towards the goal of the process.
4. The contractor shall communicate in person, by phone or in writing with process
participants to ensure that issues and concerns have been communicated accurately and
that all participants are adequately prepared for the next meeting.
5. The contractor shall provide draft meeting summaries to the PO, DOPO and the
participants. Upon receipt and incorporation of comments, the facilitator shall distribute
final meeting summaries to the PO, DOPO and participants.
6. The contractor shall provide meeting facilities and support for all meetings.
7. The contractor shall furnish a draft final report of the allocation process to the PO (one
copy) and DOPO (five copies). The contents shall include:
(a) A two page executive summary of the process including the background, the
issues discussed, and the resolutions of the issues;
(b) Final meeting summaries with relevant and necessary attachments;
( c) Copies of all documents compiled by the allocator during the allocation process;
( d) Relevant substantive correspondence between the allocator and the participants
and between the participants themselves (if available to the allocator); and
(f) A process evaluation by the allocator summarizing results of the process, analysis
of issues and balance of parties, procedural lessons learned, and recommendation
for improvements.
The PO and DOPO will review the draft final report and provide comments and revisions as
necessary. The contractor shall prepare the final report incorporating its comments and revisions.
The contractor shall provide 2 copies of the final report to the PO, and 5 copies to the DOPO,
and one copy to each party involved in the process.


2015-05-20 – EPA – West Lake Landfill – Potential alternate waste streams not specifically Leached Barium Sulfate

Hooper, Charles A.[[email protected]]
Vann, Bradley
Wed 5/20/2015 3:05:48 PM
RE: Recent CAG question
From: Hooper, Charles A.
Sent: Wednesday, May 20,2015 10:04 AM
To: Vann, Bradley
Subject: RE: Recent CAG question
WLLFOIA4312- 001 – 0047457
From: Vann, Bradley
Sent: Wednesday, May 20,2015 6:39AM
To: Hooper, Charles A.
Subject: RE: Recent CAG question
EMSI: #6) Based on the results of the GCPT gamma logs … will be used to evaluate whether the
radionuclide occurrences are associated with Leached Barium Sulfate Residue (LBSR).
CAG Question 4: The Atomic Energy Commission (AEC) explicitly details how the radioactive
wastes dumped at the West Lake Landfill in 1973 consisted of more radioactive wastes than
“Leached Barium Sulfate Residue” in its 1974 decommission report on Latty Avenue.
EPA Response: The analytical testing being performed at the West Lake Landfill site will detect
radionuclides concentrations regardless of the CAG’s concern for its origin.
WLLFOIA4312- 001 – 0047458
From: Vann, Bradley
Sent: Wednesday, May 20,2015 6:17AM
To: Hooper, Charles A.
Subject: RE: Recent CAG question
WLLFOIA4312- 001 – 0047459
From: Hooper, Charles A.
Sent: Tuesday, May 19,2015 3:14PM
To: Vann, Bradley
Subject: RE: Recent CAG question
WLLFOIA4312- 001 – 0047460
From: Vann, Bradley
Sent: Tuesday, May 19, 2015 11:39 AM
To: Hooper, Charles A.
Subject: Recent CAG question
We received a question from the CAG regarding the ongoing GCPT Phase 1D effort. Can you
help me answer this one? Thanks,
EMSI: #7) Details 12 radioactive isotopes to be tested.
CAG: We recommend additional testing for Radium-223 and Thorium-227. If the EPA cannot
amend the Phase 1 Investigation Work Plan to include sampling for the above mentioned
radioisotopes, the CAG recommends that EPA Region 7 conduct tests for the listed isotopes in
its split samples.
WLLFOIA4312- 001 – 0047461
EPA Response: ???
Bradley Vann- Remedial Project Manager
U.S. Environmental Protection Agency
Superfund Division
Missouri/Kansas Remedial Branch
11201 Renner Blvd.
Lenexa, KS 66219
Phone: 913-551-7611
Fax: 913-551-9611
Cell: 816-714-0331
WLLFOIA4312- 001 – 0047462


2015-04-23 – EPA – West Lake Landfill – Superfund Hot Issues – SENATE APPROPRIATIONS COMMITTEE HEARINGS

APRIL 23, 2015
Issue: Lead cleanup status in Southeast Missouri Mining District (SEMO) and
Southwest Missouri Mining District (SWMO).
• SEMO: The Superfund program is addressing 12 lead mining and ore processing related sites in
the Southeast Missouri Mining District. The priority has been to prevent ongoing exposures of
residents, especially young children, to lead contaminated soils and drinking water and to develop
cost effective actions to address impacts to the natural environment for implementation in the
future. Through fiscal year 2014, over 1.8 million cubic yards of contaminated soil at over 4,000
residential properties, including schools and parks, has been addressed across a seven county
area; over 11 million cubic yards of mine waste on over 2,600 acres have been excavated and
stabilized; and 300 homes have been provided an alternate source of drinking water. Much
similar work at over 5,000 residential properties and 1 OO’s of miles of stream sediments and
floodplains along Big River and other SEMO streams remains to be accomplished across this
mining district.
• SWMO: The Missouri portion of the Tri-State Mining District is referred to as the Southwest
Missouri Mining District and includes six sites spread across four counties. Most of the direct
residential exposure has been addressed with lead contaminated residential soil removed from
over 3,300 residential properties and an alternate source of water provided to over 2,200 homes.
In addition, through fiscal year 2014, over 8 million cubic yards of mine waste on 3,000 acres of
mine impacted lands have been remediated, with over 7,000 acres of mine waste remaining to be
• Joint Missouri Lead Strategy: In 2005, EPA, Missouri Department of Natural Resources,
Missouri Department of Health and Senior Services, Agency for Toxic Substances and Disease
Registry, and U.S. Fish & Wildlife Service developed a lead sites strategy to approach the large
and growing requirements to address legacy and active lead mining and processing impacts to
human health and the environment. The strategy was updated in 2012 with an expanded set of
agencies including the Missouri Department of Conservation, the U.S. Army Corps of Engineers,
and the Missouri Attorney General’s Office. A Lead Task Force was established to develop and
oversee the implementation of this significantly expanded Missouri Lead Strategy. Building on
past progress, the updated strategy addresses the entire scope of the human health and
ecological problems created by the legacy and ongoing mining practices. Many of the remaining
problems will be complex and expensive to address, making communications and outreach
activities essential to securing resources and acceptance of future actions.
• Much progress has been made to address the human health impacts of the historic and ongoing
mining practices in Missouri, and work is underway to address the remaining lead contaminated
residential properties and assess and address the ecological impacts.
• Negotiations with Doe Run are ongoing to address the cleanup of lead contaminated residential
properties identified in the 2011 ROD for OU01 at the Big River Site. The ROD estimated 4,000
residential properties requiring cleanup at an approximated cost of $130 million.
Contact: Gene Gunn, 913-551-7776
WLLFOIA4312- 001 – 0056389
Issue: Ellisville Superfund Site cleanup- (Strecker Forest Area)
Background/Status: EPA recently concluded a Superfund removal action at the site, an action
which began in March 2014 and was completed in March 2015. The action successfully removed
residual dioxin contamination in several areas of the site, and included environmental use controls for
a portion of the site that were developed in coordination with the Missouri Department of Natural
Additional actions are possible at the site (e.g., additional environmental use controls). EPA
continues to engage with the City of Wildwood, the City of Ellisville, and residents of surrounding
communities in resolving any further issues/concerns. EPA has strived to be as open and transparent
as possible in information-sharing and discussions, and has valued the relationships that have been
established with this local community.
• EPA recently concluded a Superfund removal action at the site, removing contaminated soils
and establishing environmental use covenants at portions of the site
• EPA continues to engage local leadership in resolving any further issues/concerns.
Contact: David Williams, 913-551-7625
Issue: West Lake Landfill Superfund Site
The West Lake Landfill Superfund Site is located in Bridgeton, Missouri. It is a 200-acre municipal
landfill site consisting of the State-permitted Bridgeton Sanitary Landfill and several older, unregulated
landfill areas. EPA placed the site on the Superfund National Priorities List (NPL) in 1990. Two
unregulated areas of the landfill, identified as Operable Unit (OU)-1, became radiologically
contaminated in 1973 when 8,700 tons of leached barium sulfate (a uranium ore processing residue)
were mixed with approximately 38,000 tons of soil and used as daily cover in the landfill operation.
The remainder of the site is included in OU-2, which consist of the Bridgeton Landfill (or Former
Active Sanitary Landfill) and two others, the closed Demolition and Inactive Sanitary Landfills are not
contaminated with radiological materials. The Inactive Sanitary Landfill is being address through EPA,
as it closed prior to existing state regulations. The other two have been deferred to the Missouri
Department of Natural Resources (MDNR) in accordance with their existing permits and post-closure
The selected remedy in the OU-1 May 2008 Record of Decision (ROD) is to contain the waste
material in place through construction of an engineered landfill cover, and implementation of a longterm
monitoring and maintenance program. Based on a high level of public and political interest in the
OU-1 remedy, which contains the radiologically impacted materials (RIM), EPA decided to conduct a
supplemental study that evaluates full-scale excavation of the radiologically-contaminated landfill
material with either off-site disposal or on-site disposal in an engineered cell. The responsible parties
agreed to perform the supplemental feasibility study (SFS) under the existing administrative order on
consent. However, the estimated costs defined for each alternative in the SFS report exceeded the
threshold value, which triggered review by EPA’s National Remedy Review Board (NRRB) in early
2012. The NRRB then provided recommendations for additional studies relating to the SFS
Report. These include: evaluating additional groundwater sampling to refresh the data; conducting a
groundwater fate and transport study, conducting a more detailed study of a partial excavation
WLLFOIA4312- 001 – 0056390
alternative where only the most-contaminated material is removed, evaluating alternative landfill cap
designs; and conducting a more detailed analysis of potential treatment technologies for the RIM.
In June, 2012, EPA Region 7 tasked the PRPs to conduct these additional studies. The PRPs
conducted four rounds of additional groundwater sampling in 2013-2014. EPA then tasked the US
Geological Survey (USGS) to help evaluate and interpret the new groundwater data. Once all of the
additional remedy studies are complete, the SFS shall be revised and EPA will release a new
proposed plan for an amended remedy and will take public comment on this proposed plan.
In addition to the remedy, since 2010 a subsurface smoldering event (SSE or pyrolysis) has occurred
within the adjacent Bridgeton Former Sanitary Landfill, which is one of the non-radiologically impacted
landfills deferred to MDNR. The SSE began to receive extensive press coverage in late 2012 when
odors from the SSE or pyrolysis increased and generated complaints from local residents and
businesses. The Missouri Attorney General’s office filed suit against the landfill owner (Republic
Services) on March 27, 2013 alleging violation of a number of Missouri environmental laws. The SSE
area is more than 1,000 feet from the nearest area where radiological waste is located. In 2013 the
State of Missouri filed a lawsuit against Bridgeton Landfill, and is requiring them to actively monitor
the movement of the SSE.
Republic Services agreed to install the second and final contingent remedy called for under the AG’s
Order, which is the subsurface isolation barrier between the North Quarry landfill cell of the Bridgeton
Sanitary Landfill, and Area 1 of OU-1 that contains RIM. Republic’s contractors did an initial
subsurface gamma survey of the area which lies within part of OU-1 Area 1 in October and November
2013. However, early results from this survey identified previously undiscovered RIM at depths of 25
or more feet to the southwest of OU-1 Area 1. In response, the additional core sampling began in
January 2014 defined the extents of the RIM, which helped Republic select a location for the isolation
barrier that does not disturb it.
With technical support from the U.S. Army Corps of Engineers (USAGE), EPA Region 7 has been
working concurrently with the PRPs to evaluate the engineering feasibility of constructing an isolation
barrier at the site. As part of this effort, the PRPs for the West Lake Site recently agreed to perform
additional characterization this year to further define the extent of RIM located outside of the
previously-defined Area 1 boundary.
• With regard to the OU 1 ROD and SFS and additional studies, the high level of interest in West
Lake Landfill has compelled EPA to undertake these steps to further demonstrate to the public
that the eventually-implemented remedy at OU-1 is protective of human health and the
• The USGS released their groundwater findings in a December 2014 report and will continue to
support EPA technically throughout the pending groundwater fate and transport study.
• EPA sent a letter (April 20, 2015) to the responsible parties requiring additional RIM
characterization work in OU 1 Areas 1 and 2 in support of the partial excavation remedy
evaluation and selection of excavation alternatives. Acceptance and negotiation for this
additional work is pending.
• With regard to the isolation barrier, EPA sent a letter (January 15, 2015) to the responsible
parties requesting additional RIM characterization between OU1, Area 1 and the Bridgeton
Landfill. Following a technical meeting on January 23, 2015, the responsible parties agreed to
perform this additional characterization. In March 2015, EPA received the responsible parties’
work plan addendum, reviewed it and submitted comments for revision. The revised document
was received by EPA on April20 and is currently under review. EPA anticipates this work to
proceed in May and be complete this summer.
WLLFOIA4312- 001 – 0056391
• Pyrolysis Analysis: EPA is working with the Office of Research and Development, USAGE to
develop a set of analytical methods to test RIM under conditions consistent with the SSE at the
Bridgeton Landfill. The intent is to determine what (if any) affect the increase in temperatures
will have should a pyrolysis occur or come in contact with radionuclides in the RIM. EPA
intends to complete this analysis concurrently this year with the additional site RIM
• EPA continues working with the responsible parties to ensure all of the additional remedy
related evaluations (as recommended by the NRRB) are completed and meet the highest
scientific standards.
EPA continues coordinating with the MDNR and the Missouri Attorney General’s office for all matters
regarding the site at either OU 1 or OU2.
Contact: Jeff Field (913) 551-7548
Issue: Carter Carburetor Site
The Carter Carburetor site is in an Environmental Justice community, including two dilapidated
buildings and two associated vacant lots in St. Louis, Missouri. The primary contaminants
found at this site include poly-chlorinated biphenyls (PCB), Trichloroethylene (TCE) and
asbestos. The site is in a commercial area with nearby residential areas, and a Boys and Girls
Club across the street to the north. The EPA has identified two Potentially Responsible Parties
(PRPs): ACF Industries and Carter Building Incorporated (hereinafter ACF and CBI). ACF
was the former owner of the buildings; CBI is the current owner of the buildings. ACF (under a
CERCLA Administrative Settlement Agreement and Order on Consent) has spent several
million dollars identifying the extent of contamination and quantifying the potential human
health risks at the site. ACF has prepared an Engineering Evaluation/Cost Analysis (EE/CA)
laying out several cleanup alternatives for four distinct areas of the site: the CBI Building, the
Die Cast Area, the former aboveground TCE storage tank area, and the Willco Plastics
The EE/CA was finalized and submitted to the public for comment in September 2010. After
extending the public comment period several times, the EPA received numerous comments on
the EE/CA. Responses to all substantial comments received from the public were documented
in the site Responsiveness Summary. Taking into account comments from the community, the
Region 7 Administrator signed an Action Memorandum in March 2011, which documents the
appropriate removal actions to address contamination in each of the four areas described
above. In December 2011, ACF voluntarily completed installation of a fence around the site to
prevent unauthorized access and entry into the contaminated buildings.
The EPA completed negotiations with the PRPs and submitted the Settlement Agreements to
the public for comment. Comments were received and evaluated, responsiveness summaries
were prepared, and the Agreements became final. As part of the negotiations, the EPA agreed
to remove debris from the building (which belonged to previous unknown tenants) which is
potentially asbestos-contaminated. This fund lead action was performed pursuant to an action
memorandum signed by the Regional Administrator and, due to the potential for asbestos in
the debris, concurred upon by EPA Headquarters, Office of Emergency Management (OEM).
EPA completed the debris removal in the fall of 2013. Debris was either recycled or sent
WLLFOIA4312- 001 – 0056392
offsite to a disposal facility. The OSC will continue to conduct periodic inspections of the site
for possible entry by unauthorized persons. Any entry points will be secured as necessary.
The PRP began removal actions on April21, 2014 and to-date has completed more than 85%
of asbestos abatement, lead paint removal, and power washing of the building interior in
preparation for demolition. Asbestos abatement currently continues at the site and the PRP is
obtaining bids and evaluating contractors to begin demolition of the buildings and excavation of
the contaminated soil. This work is expected to begin during the summer of 2015.
• Talking Points
Contact: Scott Hayes, (913) 551-7670
WLLFOIA4312- 001 – 0056393


1988-01-29 – NRC Memorandum – Procedure Regarding Radioactive Waste in the West Lake Landfill

MEMORANDUM FOR: Stuart A. Treby, Assistant General Counsel
for Rulemaking and Fuel Cycle, OGC
FROM: Richard E. Cunningham, Director
Division of Industrial and
Medical Nuclear Safety, NMSS
This is a request for advice regarding what legal recourse we have to require
a former licensee, the Cotter Corporation, to properly dispose of radioactive
wastes dumped in the West Lake Landfill (Docket No. 40-8801.)
In 1973, some 8700 tons of radioactive leached barium sulfate wastes from
uranium ore processing were nixed with soil and dumped in the West Lake Landfill
on the outskirts of St. Louis, Missouri. This action by a contractor for the
Cotter Corporation was taken without NRC authorization.
We have reviewed NRC contractor reports of field investigations of the
West Lake Landfill, NRC records and information from the Missouri Department
of Natural Resources. Based on this review, we have prepared a Draft Summary
Report which discusses the radiological and environmental circumstances of
the wastes. From this review, we have concluded that remedial action is called
for, but that additional technical information and engineering evaluations are
necessary to determine how it should be accomplished. We also need to determine
who should be responsible for conducting the studies and the remedial action.
Enclosed is a copy of a letter from Region III to the Cotter Corporation, dated
June 11, 1976, transmitting inspection reports that provide a history of the
wastes in the West Lake Landfill and a copy of the Draft Summary Report. If
cdditional Information is necessary for your determination, please contact
L. Rouse or J. Swift of my staff.
Stuart A. Treby 2 2 9 1988
It is important to act promptly on this matter, because the disposition of the
West Lake Landfill wastes has been raised as an issue with regard to negotiations
over which State will host a compact’s low level waste burial site.
Original Signed By:
Richard E. Cunningham, Director
Division of Industrial and
Medical Nuclear Safety, NMSS
1. Draft Summary Report “Uranium Ore
Processing Wastes in the West Lake
Landfill,” draft of January 28, 1988
2. Ltr of 6/11/76 to Cotter Corp.,
fm JMAllan, RIII with enclosed
inspection reports on Cotter Corporation’s
Latty Avenue site/dumping in the West Lake
DISTRIBUTION NMSS 87082& w/encls
Docket No. 40-8801 IMSB R/F NMSS R/F
NMSS Office R/F IMNS Central Files CJenkins
CEstep LCRouse JJSwift
VLTharpe GLaRoche .
— — ^,-y^z^
LRo’use: : GLSjoblom: : “-RtCUfTntngham:
DATE; 1/^/88; : lM/88: M /88;


1971-07-22 – AEC – Cotter Corporation – Radioactive Waste Disposal Documents

WASHINGTc:>N, D.C. 20545
() . rt/
JUL 2 2 1971
Ulys_ses l>f. Stae1Jler, OCN
On June 27, 1971, Hessrs. :HcGrath and Marcott of the Cotter Corporati.on
met 1·1ith members of our regulatory staff to discuss possible on-site
burial of radioactive ~-1astes at their Hazeh1ood,·Hissouri, site. At
that time it 1•1as explained that before ~.Ye lvO\tlcl be able to determine
whether, and under ,.1hat conditions, such burial could be authorized
w·e would need a complete description of:
1. The radioactive ~-7astcs involved (including principal radioisotopes
and activHies).
2. The ~roposed method o£ burial.
3. The burial site, including geographic, hydrologic, and geochemical
parameters which might affect miRration of the radioactive material
from the site.
It w·as also pointed out that Cotter Corporation might be required to
provide for perpetual maintenance of such a burial site and submit an
environmental statement in accordance tdth the National Environmental
Policy Act if it appeared that this on-site burial could significantly
affect the quality of the human environment.
Since the June 29, 1971, letter from Hr. l.fcGrath indicates that Cotter
Corporation is preparing to submit more detailed information on their
proposal, you may H:f.sh to include in your reply to this letter the
enclosed. documents, entitled “Licensing Requiiem~nt for Establishment
of a Land Burial Facility for Burial of Radioactive \rlastes” and
. ~ ,, ‘ .. , ….. \
~ ~
.. ‘” .,.,.,”‘· .-.,, … f.
·· ~ ··· ·· L<;>tl~.(-.. -~~q.<>.t~\..\.1′.’)_.!
. I
·······:·•· … . …….. , ……………… ; …………….. ·····r·
Ulysses H. Staebler 2
“Guidelines for Decont ami nation of Facilities and Equipment Prior
to Release for Unrestr i cted Use or Termination of Li censes for
Byproduct , Source, or Special Nucl ear HAter.ial.”
Enclosures :
1. Li censing •••
2 . Guide •• •
f))l#—-. C. L. Henderson
Assistant Director of Regulation
for Administration
‘ ‘
The land on which facilities for burial of radioactive wastes will
be located must be owned by the Federal Government or a State
Government. Section 20. 302 ~ 10 CFR 20, “Standards for Pro tee tioh
Against Rsdia tion 11 , provides that the Commission \11111 not approve
an application for a license to dispose of waste material by
burial in the ground o.n land not owned by the Federal Government
or a State Government.
. .
An application for a license should inc ~ude the fo llol-lihg. infor•
mation: · · :.
1. Total amount of byproduct material in curies,· source
material in pounds, and special nuclear material in
grams v1hich wil.l be possessed at any one timeo
2. The qualifications of the applicant and members of his
staff to ·engage in the proposed ac tivities9 including .
specialized training and experience in handling r~dioactiva
materials and dealing with radiation problemso ·
;3.:. A description of the radiation detection instrume·nts which
wi 11 be available, inc.luding the manufacturers 1 model numbers,
the sensitivity and range of the instrumen’ts., and the f:raquency
and method of calibrationo . ·
4. The r.~diation protection procedures including emergency
pro~edureft for each phase of ~he proposed programo
•’ . . _ _,,., .,..
5. A description of the .facilities that will be used·.for
storage including: .. ···
A. ‘Address
B. ·Nature of su~roundin~ area (i<>e., residential,· .i~dustrial) ·
. · …
c’; ‘Size ··of.· surrounding .. -~r~a con trolled by .. the, applicant
·n. ··sketch sho,-1ing loc·ation of building,’ portion of building
~·to be used for proposed licensed operations, identity and
locat~~n of other occupants (if any), and distances to
nearest other occupants and to nearest. ad joining occupants o ..•
· ·. I ) { } J .•: /\ V~. (.~ ·~~:~.tV J::~:.~;.;;
All licensees are required to comply with the Commission.’ s radia ti’on
protection regulations, Title 10, Code of Federal Regulations~ Pat’t 20,
“Standards for Protection Against Radiation11 o This regulation estathishes
radiation exposure standards and precautionary proqedur~s _ ~hich must be
follo~1ad in handling licensed materiaL. Standard>,6p~raJ;ipg proqedures
should be based .. on fulfilling the requirements of. ~his:·regulationo . . ~ ·. :· ~ … :: . ~
. :
\-lith respect to the site and land in which wastes will be buried,
the applicant must include an analysis and evaluation of certain
information as to the nature of the enviroment including topograph””
ica 1, geographic a 1, me terorologica 1 and hydro logic a 1 charac ter:i.s·tics,
usage of ground and su.rfaco waters in the general area, and the n·at:ure
and location of other potentially affected .facilities. More specifi~
cally~ the following hydrological and geological information should be
·sumitted as pertinent and appropriate to the site under consideration:
1. Geologic .Framework
·A. Maps sho~oling surface and subsurface distribution of p·ertinent
rocks and sediments and their relations to topographic, hydroQ
graphic, and cultural features at the site and in the surround~
ing areas that might be affected by activities at the site.
B. Subsurface geologic data on pertinent rocks and seaiments at
the site and in the surrounding areas that might be affected
by activity at the site.
1. Logs of wells on and near the site, including descriptive
lithologic logs and geophysical logs of wells or test ho l es
at the site4
“., 2 . Correlation diagrams and vertical cross .sections that sho”\v
the lithology and continuity of pertinent subsurfac~ forma=
tions and their relations to surface t-opography and geology,
hydrology, and cultural features4 /
C. Data on geologic structures such as folds, faults, and joints.
lL Hydro logy /
Ao Surface water
1. Description of all pertinent surface~water features such as
lakes and ponds and drainage netv1orks of intermittent and
perennial streams, both at· the site and in the surrounding
areas that might be affec t ed by activities at th~ siteo
2. Uses of surface water on and adjacent to the site, including
quan.tity used in relation to maximum and minimum stream flows.
,; ·’ 3. Chemical quality of sur~~ce \·later.
4. Relation of surface water to gr ound ‘ivater, particularl)i in
context of areas of surface=tva ter infiltration and ground”‘·
water discharge that might affect the movement of radioactive
materials on or away from the site.
‘ I

! r
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• •• J • •
…. 3·
B. Ground water
1. Description of the occurrence and chemical quality
of ground water in relation to the geologic frame~.~
-..·1ork ..
a . Generalized regional picture of occurrence ,
altitudes of ‘”ater table, and piezometric surface,
documented by adequate data from inventories of
\vells in areas adjacent to the site.
b •. Detailed “descri ption of pertinent-aquifers at
at the site documented by adequate dated f rom
hydrologic te s tingo
2. Movements of ground water
a. Areas and mechanisms of recharge, both -regional
and at the site o
b. Directions of movemen~both regional and at the
site ..
c . _Areas and mechanisms of discharge, both regional
and at the s i. te o
/ Rates of movement as calculated from acqu_ifer
coefficients determined by pumping tests at the
s i te and by ,.1hatever addit ional data are available
on a regional basis o
e. Fluctuations of -.,qater leve ls and other hydrologic ..1 parameters as the result of natural seasonal or
climatic fluctuations, or as the result of man’s
ac t ivities such as pumpage from wellso
:,3. Use of ground -..vater at the .site and in adjacent areas,
documented by inventories of -..vells.
b. Type of use.
c . Pumping rates and schedul es.
d. Projected future water use.
III. Geochemistry .. ~on exchange characteristics of soil in
\vhich burial trenches ‘vould be excav ated .
I !
I i r !
I I.
” f
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IV. Monitoring
A., Plans for monitoring soils and v7ater in the context
of the total ~valuation of geology_ a~d_ t1y<;1rol9gy., ~ ~ B., Plans, if any, for monitoring ~vater offsite·; for instance9 periodic sampling of exi~tini wate~ w~iis nearby and down the ground="Y7ater gradient from the site-. The transportation of radioactive material in interstate commerce by rail· or ·public highway is· governed by Department of 'l'ransC>
portation regulations., A~ so~ similar regulat~ons . have been . ·. _ ..
adopted by the U” So Coast Guard for transportation by ~.jater” .
When these regulations are not applicable 9 such as in ~nt~astate
·transportation, AEC \vaste disposal licensees must conqu~t ·_their
transportation in accordance with a license ~ondition which
establishes requirements and contains specifications similar
to those of the Department of Transportationo
It is the policy of the AEC to publish a notice of proposed
issuance of a license permitting the conduct of a commercial
radioactive waste disposal service in. the Federal Register
·after the application has been revie\-led and the AEC
· fin.ds that the applic?nt can conduct the proposed programsafely
in compliance with current regulations and req~ire~
ments,. The notice specifies that a formal hearing ~.;rith
respect t o the is suance of the license may be requested
by the applicant of an intervener within fifteen (15) days
after the publication of the notice, pursuant to the .pro=·
cedures contained in the Commission’s . “Rules of Practice”t
Title 10, Code of Federal Regulations, Part 2o If a formal
hearing is not requested ‘o}ithin the specified period, and in·
·the absence of such public interest as -to warrant the Commis~
sion calling a hearing on its o’·m motion~ the license is
issue do
Section ·2.,101, Title 10, Code of Federal Regulations 9 Part-‘2,:

1Rules of Practicetc, requires that a copy of ·an application
for a license to receive waste material from other persons
for the purpose of disposal shall be served by the applicant
on the chief executive of the municipality in \>1hich the ·
activity is to be conducted, or if the activity is not to
be conducted within a municipality, then on the chief
executive of the countyo
;’ _
) J,., ‘
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* -··
.· ,.
PRIOR TO RELEASE I<'OR UNRESTRICTED USE OR TEP.MINATION OF LICENSES FOR BYPRODUCT, SOURCF., OR SPECJAL NUCLEAR !ljA'J.'EHIAL U. s. Atomic Energy Commission Division of Materials Licensing · . Hashingto~, D. C. 2054-5 APRIL 22, 1970 · ,· 0. ~. .. ., ). ·, .· ... # __ . .. 4J.'he instntctions in this guide :in conjunction Hith Tablec I and II spec.i. fy the raclioacti v':i ty and rudia ti on expos u ce rate l im:i ts ,_.hich chould" be tt:>ed in accomplh;hi ng t h-: deconte.mination and survey of
s urfaces of prcmiGes and equipme.nt prior to a.bandonroeht or relea~e
for unrentr).cted use. The l ili’li ts in ‘l’ables I and II do not apply
to premises , equipment, or scrap containing induced r adioactivity
fo-r 1-1hich 1:-hE: racUo1ogical conside:rations pertinent to their use·
may he d.i fferent. ‘.l’he release of such facilities or items from ·
regulatory control Hill be considered on a case-by-case basis .
1. The licensee shall make e. r easonable effort to eliminate
. retiidu3l. contamins.tion.
2. Radioacti.vi ty on equipment or surfaces shall not be covered
by paint, platinB, or other covering mat eri al unless contumination
J.eve.ls, as detemtined by a survey and documented:
··are belo,·t t he limits spccifieq. i n Tables I or ·II prior to
applying the covering. A r easonable effort must be made to
minimize the contamination p.r.ior to use of any covel.·ing.
3. The. r adioactivity on· the interj.or surfaces of pipes, drain
lines, or duchrork shall be determined by making measurements
at aD. trapi’;; anc1 oth~r a.pp~;·..opri ~.te access pcir!te; provided.
that contamination at these l ocations is .-likely to be representative
of contaminatton on t he interio~ of t he pipes, drain
lines, or ductr,.rork . Surfaces of premises ; equipment, or Gcrap
vrhich a:ce likely to be contaminated but are of such size,
conot’ruction, or location D.s to make the surf’ace inaccessible
.. for purposes of measurement shall be presumed to be contandna.ted
in excess of the liut.i. ts.
.. . .. …
l~. Upon request) the Commission ro.ay authorize a licensee_ to relinquish
possession or control o:f:’ premises, equipment, or scrap having
surfaces conta!crim{ted \-lith ·ma.teriaJ.s in excetis of the l inli ts
specif i ed. ~li s may include, but would not be l imited to) special
circums tances such as raz ine of buildings, transfer of premise:>
to anot her organization conttnuing ‘vork \lith radioactive materials,
or conversion of facilities to a. long-term s~orage or standby
status. Such requests must:
a. Provide detailed, specific information describing the premises,
equipment or scrap, radioac tive c;ontamtna.ntsJ and the nature,
extent) nncl degl.’ee of residual surface contominati o~j(_H~~ /\ \tCH(V;?.’<' b. Provide a detailed healt h and saf ety analys i s \-lhich _reflects that the residual amounts of matcriel.s en· surface areas, together vTitb other considerations such as prosp_ective use of the premises, equi.pment or scrap, are Wllikcly to result · in an tmreasonable risk· to the health and safety of-the public . - 2 5~ ·Prior to release of premises for unrestricted use, the licensee shall make a comprehensive radiat:~,_in survey whi.ch establishes that contamination is -vri.thin the limits specified in Tables I or II. A copy of' the survey report shall be filed \vith the DirectorJ Division of · .,_. MatcTi.a.ls Licensing: US.Al!:c/;..;.'~·.~-shington, D. C. 2051~5, and also the . · ·<"YH1'ector of the Regional.'Di·.vision of Compliance Office having - ·jurisdiction. The report should be filed at least 30 days prior to the planned date of abandor~ent. The survey r~port shall: a. Identif.y the prcnuses. b. Sholf that reasonable effort has been made to eliminate residual contamination. c. Describe the scq~e of.the survey and general procedures followed. d. State the ~indings of the survey in units specified in the instruction. t) rr. ~' ~·~~ /\J~J .. ; .~:.t .t. \' tr~~~:·~ li'ollo-:rh-232, and . 5,000 2 dp~ ojlOO em .1,000 dpm a./100 ct:l.
associat ed decay products – i ‘M.a.ximt!to I 25,000 G.pm JlOO 2
: em
Other isotopes ‘tvhich decay 1,000 d:pm o/100
em 100 dpm a./100 em 2 ·Average ( 6) 2 by alpha eoission or by : 500 dpt’l o/100 em 100 .. dpm r:x/100
spontaneous fission ::” I Maximu:o
dp:n · ·wloo· f_m2– .. ., .;.~. 2,500
I · ~ … ;. ;.,: ., :;I cm(5) 2 Av~rage (6) Beta- ga.mma emitters (iso- ,., . 0 . 4 mrad/hr at 1 . 1,000 dpm ry/100 em . (5) 2 topes “tdth decay modes :•··· 0. 2 tlr ad /h.: ~·t lcm 1,000 dpm ~-y/100 ,:~ ‘
other tha:1 alpha e:c.issi on .~. .·. – . Ha:ximum or spontaneous fission) r … ~ 1 .0 mrad/hr a t cm(S) ,
…. !:, .J..
•, .•. . • .
. . fl> .•
(1) E i~her Table I or ‘table II may be used . For e…-ca:cple, if all beta-gamma r eadings were less than 0.4 mrad/hr a t 1 em,
Tab~e I could be used; but if the maximum reading were 0.8 mrad/hr, mat e=ial could be released under Table II provid~
ng·the average was less· than 0 .2 mrad/hr.
(2) t~er e surface contamination by both alpha and beta- gamma emitting .isotopes exists, the limits established for alpha
and beta-ga.n:.ma emitting isotopes shall epply independently.
(3) As – • . “· ‘•f•t
.- .,, .. . _.,. -~! .
Mr. Edwar d J. Mc Gra t h .. : I
260 East Jefferson Street
Rockville , Naryland 20850
…….. ~
~ ‘
… …….. . ”• ····· ,. :•· ········ :- -,, . ~
Dear Mr. Mc Gr a t h :
t . • •••••• ·:· . …. .. •’ ””;l!<::~ ~. ~ .. ··~· ·····:·~·.! .- , .... ·· ··· ·-~ .... -. . : ' ! •' •': ,: • ••• ~· . ... ~ • ••• , '·:--· ... .... ... ~! Thank you f o r y.o ~ r l e t t er of June 29, 197.1. I beli eve you are now in d irect cont a c t wi th the proper organizations· within the Atomic Energy Commi ssion to provi de an~:n,,crs t o your. ques t ions rela t ed to d ispos a l of r adioac t ive wa s te ma t e r ial s own ed by the Cot t e r Corpo~ation . The question of burics.l of the materi 20850.
June 29, 1971
The Honorable ~fj,lfrid E. Johnson
. U.S. Atomic Energy Comm1ss’ion
Washington, D.C. 20545
Re·: Cotter Corp_Q}:”ation- Radioactive vlastc Disposal Prooosal
Dear Commissj.oner Johnson:
I Pursuant to .your suggestion made during ou.r’ conference
on Ju~e 24, 1971, I am enclos1.ng copies of the corresponde:t..ce
between Cotter Corporation and the Co~~ is sion relati ng to the
disposal of radioactive waste materials owned by the corporation,
‘·rhich are novr located :i.n Haze1wood, Mj.ssouri. · ·
I am also enclosing copies of a preliminary propo~al for
on site burial prepared for Cotter Corporation by the engineering
firm~· of Ryckman, Edgerl cy, Tomlinson and Associates., In c.~
together \ Missouri. W~ will
furnj.sh you with copies of further submissions. and correspondence.·
· · On behalf of Mr. Marcott> Cotter d~rporat ion, and myself,
I wish to thank you for providing us with an opportunity to
discuss with you the problems and public p6licy i ssues which
surround our efforts to dispose of the waste materials safely
and quick4.y.
G cr.c1~~ l ;.~n! le.;::~r·
United 8~~~eA ~to~ic
Ener£;s· Co;.~r.1 1::;s1~o n
\’!~sh~.n r.:t on D. C. ~05115
Re: CottcP Corpornt1on
\·Taste Dtsposal Projcot
Dea14j !·it’ . ~·~c1J.. “J.:~.~l~:~rr;.fo:rth: ,
:~:~~~r.yJ. u.no~1. tho facts ?..nd c~L:t•ct~l:!~ tances herc1nD.f’tcl”‘ set· fol”‘th.
Co~i;0.J.’ Co-rporat-ion hereby m.::tlwa a~)pJ.lc::tt.ton fo:.., a u.tho_rity to dis-.
po:30 or rad:1.oac t:,. ve. \’111~ te ~:;.~ t0.r>io:l at ·’l.on, :tn 1967, purchaned frnm e. pr>lv~te concern
a substnnt1Ql ~uant1ty of ~adiouctlve residues storod .et that time
at. the so cal:tot”l · “n h 1 port rd. te11 in St . Louis, ~·fifHlOUl’l for the pttr~
.-.!J on. ;L,’~. of~'”-‘ ‘-“‘”r_’:”;l”.J’..”._’ “‘0C”””””<''' s .4.1. r'tcr:,.:, t'n,;~:,V~- P•O ""~' ti.J.O. ".',~.. of 1l's.h r~.; tn..:.G :\.'t.·'r".'->‘)•-•’ “1.,,~..1_ ·~·•’1’1 ‘..1…. — “l1′ \•lL•\n.. .n..” 1 (r’…;.rJ otn;; .n’-
abJ.e to t:-.•catment in tho urcm1um n~tll or Cottc!’ Cor>porn’.;ion locutea
in Canon City~ Colo~ado .
‘i’he l”‘en1.dues pnrc:1a0e:1 ucrc ·the P!’Oduct of ~~.rlier Commission
on:·:<:--6.t ions, ~n~ rc pre~en-Gcc1 u. vubstant1al problem ~ t the t.ime \·rhcn th~y \'iCre P.cqn:lrcd by co~~tcr Co:•pm?nt:lon) hcca.use t:he f:J.rm \•lhich pu.rchascd them f'x'CP:1 the Commiss·icn Emd fi>om uhich Cot~t er Corpo:;”)nt:.
1.on ecq,,t:lr>s::H.1 thor: ~~::1 (1 ~one oo speculatively, . .,._:ithout ;:. progr e.n(1 t’uboequ.cntlv tcrm~umted its business -act:l v-
!nc1n·:.1et!.tion has
tr c:·.~l3 0Q:,”‘t0d ancl proccnned ~11 of’ the ”!<1. s te r:tate~r:i.eJ. · . \'7h5.ch Has a!~U~1~i.!ble to treatr.:en·;; and made arrano~mGnts for- disp.o"oiti~n of ~ lar>ge quant:t ty of unu~abl e loose r.taterial. ·uon .6 \J.C UJ.VJi:.;J
Thor.e re:::!:lil1S for c:1Cfl03ition ~PPl;O:dr:w.tcly one thoustmd
(1~000) drurn3 f’11lensh, that ~.~ 5.tems snch
as brj.cks > clot ‘I i. n’:”·, ho0tg l gloves. ~r~d t~~(~ 11 i;·:’. ‘.::’he c:!’UQ!S nr•0
Q \~~,~·o P.!; 1._~, 1. :· -~ :\ ~ ;• ;~ r\ ~ H~H:~ l wood_, ~-!:! n n:)’.1t’ 1 •
\ ..
.. -2-
Cottc:r’ Corporat. ion J if’ au. thor lzed by th~ Commission to do 80 I
‘·Till t ranspor\: tho. dru:ns .bY truck from HLH~ehYoocl; H:l.noouri to the
qun~ry· o1te at Weldon Spring (a dis\:ance of approximateiy thirt~
(30) m:lleo) o.n(1 dcpon:Vc thm:1 in the quo.l’ry, subject to Couunlsaion
nimD.ar contaminated material; that no conflict
e;dG~~::l :!n this Gituat1o.n \·t:l:’~h the Com.lni.ssion policy against engag:
tnb ~:…;: op·~l’at:ions competitive wj.th p1.~:1.vaJ~ e .tnctustry, s1.ncc exletint:;
p:..•ivatcly oper-ated Haste · dispos~.l fac5.lities ape not clee:l;.gned
in capacity or othcrwine for disposition 6f material in the ~an- ·
t :tty and for·m invol vcd in thie !’>:L tuntion; th:.J.t tho <:lintanco to· t:he ncarGnt comr:l0j."'cJ.uJ. disposal nite, even 1·1cre i.t capable of handlinE; th0 materi~l is t·,·~o hundre(l ( 200) mil e ~ .as opposed to e. cU.st2.nce ·of thii.'t;'l (30) ni.l"Cs fi,om Ha~eh10od to Holdon Spr:tnG, ane othc.riunds or depressions. ·
It is the desire of Cotter Corporatioi1 to reutrn to its Lessor· la~d \•thich
\·till in no vmy he limited in its usefulness or va1ue and \·Jill in no way
endanger the sm-rounding environment and its inhabitants.
1″} {) L~~ t\ .r~~. (· ~· 1.·. r ·~ \f D):.~i
. •·. ……
l: .

2~ 780
– — – … · ·-·- -rc”a7’f”Eyi\v0nue – —
–~———–~ ———–
Pon ds
(/) – -………
fi GURE 1
Sketch not to sc«lc
.· . .
Co lorado

, •
• . ..~. ·f o: ·;u”f~·!:.:. ~.
l . , … ~f t\ ” f t l < ili'······' ) e., .f ' " ' I ~ ' , · · . ·coTTER CORPORATION LATTY AVENLIF. STORI\GF. ·SITE \t!J\ZLE~·IOOu, t4ISSOURI · '-' UNITED ST/,T.ES ATOMIC ENERGY COMMISSION VIASIIINGTON, D.C. 205<1S !·lr. Ed·,Jard .T. NcCrath 260 East Jefferson Street RnckviJ.J.e, ~laryl.'ll.H'I 20fl50 D~ar Mr. McGrath: MAY 2 4 1971 JQJECJEKVED MAY 231971 _·E. J. l\1cGRATH ' This is in r esponse to your l etter of April 28, 1971, proposing to di~pose of cer t ain r adioactive ·Hastes mmed by the Cotter Corporation in an AEC-oHncd quarry at Helclon Spring, Hi ssouri. Your letter sta tes, in_.part; t hn … ”
This s l:atemcnt rai ses some questions on t..rh i ch ”-‘e ~vould apprec:i.a te
ftlt’thcr in~ormation . First, Hhat :i.s the intent of t he phraGe
” or othcn·ris c=’? ~ · Does it mean that the licensed burial ground
operators couJ.d not handle the material ~dthin the safety require-
. ments of their present licenses? Second, i s t he judgment cxpress~d
in this· statement tha t of the Cotter COl.·poration or that of the
licens ed burial ~t”ound o perators? Nore spe cifica lly, h~.v e the three
l i cens ed burial ground ~~crate rs (Nuclear Engineeringj Nu clear Fu~l
Services , nnd Chem-Nucl<:'\.:lr Services) s tated that they could not handle the material? fve twuld apprecia te your vieHs on these points in order to consider the proposal further . 1)0E Sincerely, i~oq~~:~ Divi sion of Haste and Scrap Hanagement ....... ... .... . ~. \ .. . · .. 'l y;. • .... • • l••t. . ~ . . . . .. · ,_~::. ~:.:...~;...:_ .... .:....~~· .. .:.~ ...,.;..,_, .... -: ...... ~~. .... __ _,,,· , . - ·.. ~- -·. ·. ....... . _.. ..... ,; ... ·- ..... ., . ·. o _ ..,., _.., ' •••. : ' .. : ... ,:· ,.r : .-· , ,_o - ~·, ,.•:~_, , 11 ,':.:..,.,-u...-;._.;.'i - .• .-~.,_.,..: ... ,, .,.,·.~&. •~ :_· • ~•a • • •• •-· 0. . -· I I UNITED STATES ATOM !C ENERGY COMM lSSION WASHINGTON, D.C. 20S4S June 2S, 1971 HENORi\NDU£.1 FOR THE r'J.LES SUBJECT: NEE'f!NG \HTH RBPRESEN'l'Ni'IVES OF COTTER CORPORATION At the request of Senator Peter Dominick (Colorado) , · Commission e~ Johnson me t t.o~ith David Harcott, Executive Vice President, ~nd Edward McGrath, Washington Counsel, . fo r Cotter Corporation on June 24, 1971. Others attending were Dr. Martin Biles and u. M. StaebJ.er. 14essrs. Narcott and HcGrath had previously met \'lith personnel from the Divis ion of Haterials Licensing and l'fast.e and Scrap ~1anageme_nt . Cotter Corporation acquired r adioactive r e~idues from early 1\EC milling operations \•lhich had been moved from the St.· Louis Airport to Hazcl\,•ood 1 a site in metropolitan St. Louis, by a Ba ltimore Corporation Hhich Hent bankrupt. The material \·/as acquired from Commercial Di scount 1 the fin.~ncer. of the ori,gj.n~J. _ p,urc.l·~~.s.e. from the AE.C . Selected materials were sent to a plan t at Canyon City for recovery of valuable ~ine ra ls. Cotter has about 15,000 tons of materials to be disposed of in addition to about a thbus~nd drums of contaminated materials which can be disposed of. comme rcially at a reasonable cost. They are COillffiitted to restore the property on \·;hich the material is stored but have found that disposal on-sit~ is not acceptabl~ under present··:r;egulations. The $150, 000 they had ·a llow<::d for on-site disposal is to be compared \vi th an estimate of $2 million they have received from Nuclear Engineering for commercial disposal at a site about 200 miles a\vay. Mr. -Marcott \•Tould like to dispose of t tie material at the quarry formerly used by the AEC near the St. Louis operat~ons ~1hich is about -30 miles from · the Hazelwood site. Dr.' Biles revie\'/Cd the situation at the quarry , .concluding that disposal there would not be accept~ble. The ' basis for the estimate of $2 million for disposal · by Nuclear Engineering was not known but it did not seem consistent: l,vith -the usual charge or aboLtt. $0 . 7o .per cu. ft. for conuuercial disposal plus transportation. (Separate information indicates this estimat~ may incl ude decontamination of buildings at the site.) Dr. Biles suggested that· transporting the materi·al to Colorado 1.. { , v ,, r· r >; n ~~ ~-~~:~·-~
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a nd adding it to e ~ is ti ng piles of tailings there might
be wor t h exploring since t he mate~ia l i s s imila r and
w~uld be quite small in quantity relative t o these pi l es.
It was agreed that:
a) Both Cotter and AEC (Biles ) would look into
the feasibility of di ~po sa l on other tailings
piles (~ncluding lice ns i ng) . ·
b) Cotter \>IOuld provide a brea’kdO\•Tn of the $2
million estimate from Nuc l ear Engineering .
AEC (Biles) would investiga ~e the basis being
used f9r private conune r c i a l disposal —
in particular whether pricing on a unit volume
basis ·,·las reasonabl e for t his kind of material.
Cotter \·lou l d pr ovi de a summary o f t he history
of t he materia l a nd t he contract obl .:Lga t,?.ons
r e l a t ive t o ul timate disposal associated \·1ith
the va ~ i o u s trans fers .
. “2f, )r] .• ~{;–:;-:<.t 1:~/;,./ U. M. Staebler , · cc: General· Nanager ......... ... .... ---.-" ... ·- Dr. Martin Biles, OS . ~. O'Neill, Cong. Rel. H. NoHak, \vSM C. H~nderson, DR .. · \ \ • ····- "· .... . •.· .• ·. r' •• - - · ; ,\_ •.. /'.· Reference is made to the June 28, ·1971 , fi 1 e memorandum from U ~ M. S taeb 1 er, concerning a meeting with Cotter Corporatjon representatives to discuss the disposal of their residues located in the St. Louis· area. The Cotter Corporation apparently proposed disposing of their residues in the Weldon Spring quarry. We can understand some reluctance to place these materials in the quarry, since the ground \'Jatet' situation in that area is not fully d.efined and "control" could, therefore, be questioned. Two points seem w·orthy of mention in this regard. · First, the dumping of the Cotter residues in either the quarry or the pits at ~leldon, Spring would represent an -exception to the radioa~tive waste burial policy as reflected 1n AEC 180/23. The possibility of establishing a troublesome. precedent should therefore ·be recognized. Second, - the negotiated sales . a9reement with Cotter stated the intent of the agreement to be the relllOVal of all residues, and specific effort \'las made to prevent a "creaming" of the material. Remova 1 from the Hazelwood site was therefore a recognized responsibility .of Cotter•s. --~-------------~~-~ ~ ._ ___ . , _ _ ...... ..... ..;.;..-._., __ ••.. .• ,\,' -i If Headquarters determinest however, that disposing of the Cotter residues_ at Weldon Spring should be approved, we believe that there is a much more acceptable alternative in the Weldon Spring area other than the quarry. The AEC-controlled raffina'te pits at the Weldon Spring site are excellently contained and isolated from the -environment. The Cotter residues are quite similar to what is a1r·eady contained in the pits and represent perhaps a · 10% addition to what is already there. There is .already about.,~ ~illiOB cubic feet of material in the pits, and the Cotter residues woul.:i 1 I ‘·!C t:i n:r 31
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Martin B. Biles – 2 – July 14, 1971
be dumped directly into Pit 4, than to transport them across country. AEC
could conceivably negotiate a charge to Cotter for disposal in the pits,
based either upon current commercial rates, or upon our cost of 11directing11
the operation at our end, plus some crudely estimated cost for later
stabilizing the residues. .
We would be pleased to assist further in this matter if requested. As you
are a\’/are, the Genera 1 Manager would have to approve acceptance of offs i te
radioactive wastes at an AEC facility.
cc: J. A. Erle\’line, AGMO, HQ
F. P. Baranowski, P, HQ
H. A. NOI’Iak, Wm, HQ
‘~s. R. Sapirie
Oak Ridge Operations
… , ·.:·· \::
WASHINGTON. o.c. ~O!:i45
Mr.· Edward J. McGrath
260.East Jefferson Stree t
Rockville1 · Maryland 20850
Dear ~JX. McGrath:
.July 22 1 1971
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~hank _ ybu for your lett~~ of June 29, 1971. I believe
you a.re nmv in dir ect contact with the proper organi ?.a·tions
Hithl n the Atomic Energy Commission t o provid~ ans\’lers to
your questions re ~ at e d t o ~isposal o f radioactive waste
mate rials Ot.vned by ·the Cotter Corporati on.
The question of· burial of the material at th e . Haz ~ lwood,
M-issouri·, -site or any other prope rty .c on.troll.cd by Cotter
Corporation should be pursued _,..;ith ·the Divis ion of ~at e ri al s
tic~ nsi ng. Any. questions you may have r e gar ding -burial of
these materials on AEC s ite s s hould be addressed to t he
Divisi011 of Waste and Scrap Manag~en t.
Should there be any f u rther que st.ions, these t\·m Divisions
will either be abl e to answer them or will ens ure that other
appropriate Divisions· \v.i,ll ans~vet~ them f or you.
w:¥~7′ Comm1.ssioner ·
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..~. ·:. ~ :~.:. I .. , 1,:·: (. “” • .:.) f ‘:< .-. .. ~ I. • ~ ... ..... ........ UNITED STATES ATOMIC ENERGY COMMISSION MEMORANDUI-1 'FOR THE WASHINGTON. D.C. 20545 June 28,·7 FILES ---~· SUBJECT: ' MEETING WITH REPRESENTATIVES OF COTTER CORPORATION At the request of Senator Peter Domi nick (Colorado) , Commissioner Johnson met with David Marcott, Executive Vice President, and Edv1ard McGrath, Washington Couns ~ l, for Cotter Corporation on Ju'ne 24, 1971 . Others . attending \vere Dr . Hartin Biles and U. M~ Staebler. Messrs. Narcott and McGrath had previously met with personnel from the Division of Materials Licensing and Waste and Scrap Management. Cotte~ Corporation acquired radioactive residues from early AEC milling operations \vhich had . been moved· from the St. Louis Airport to Hazeh!Ood, a site in metrop9li tan · St. Louis, by a Baltimore Co~poration which · w~nt bankru~t. · The material \'las acquired fr~:>n\ Connnercial Dis.co~nt I the
.financer of t:he original purch.ase f.r.om the AEC. Selected
materials ‘Vlere sent to a plant at Canyon City fo·r -recovery
of valuable minerals. Cotter has about 15,000 tons of
materials to be disposed of in addition to about a thousand
drums of contamirHited materials which · can be disposed of
con~ercially at a reasonable cost. They arc committed
to restore the property on which the material is stored
but have found that disposal on-site is not acce,ptable
under present regulations. · ·rhe $150 , 000 they’ had allowed
for on-sit~ disposal is to be compared with an estimate
of $2 million they have received from Nuclear F.nginoering
for commercial disposal at a site about 200 miles away.
Mr. Marcott t,o;ould like to dispose of the material at the
quarry formerly used by the ·AEC near the St. Louis.
operations \•lhich is about -30 miles from the Hazelwood
site. Dr. Biles reviewed the situati on ~t . thc_quarry 1
concluding that disposal there would not be ~c·ceptable.
The basis for the estimate of $2 million for di spo~al
by Nuclear:: Engineering \’las not knovm but it did not
seem consistet?-t \ • … ” :~ • ·1.~. ‘\, \
; .
”2J, ) 71, .467-X-t.evv
U, M. St aebler·
· 6c: Ge ne~al Manager
Dr . Martin Bil e s , OS
R. O’Neill , Cong. Rel .
H • Nowak , Y.1SM
C. H~nders on, DR
H. Ililc~
E .. ·l60
f<. Fatllkne:r P-1120 . il. ROWi!X G-117 C. Ue.t\tku:aon J~..ttn~ R. Cunninqharo OS:lS 58.94 7/14 respon.s~ .. LAW OFFICES EDWARD J. McGRATH 280 EAST J EF"FE:RSON STREET RocKVILLE, Z.!;. RYt.AND 20850 130 11 4:> ~- 470 7
June 29, 197f
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The Honorable Wilfri d E. Johnson
U.S . Atomic Energy Conunission
Washington, D.C. 20545
Re·: Cotter Corporation- Radioactive vlaste Disposal Propo’sal
Dear Commissioner Johnson :
Pursuant to your suggestion made during our conference
on June 24, 1971 , I am enclosing coptes of· the correspondence
between Cotter Corporation and the Commission relating to the
disposal of radioactive vraste materials ovmed by the corporation,
v1hich are nm’l locat~d in HazehTOod, Missouri. ·
I am also enclosing copies of a preliminary proposal for
on site burial prepared for Cotter Corporation by. the engineering
firmoof Ryckman, Edgerley, Tomlinson and Asso~iates, Inc., ·
together 1’li th a copy of a memorandum by .Mr, · l•larren Goff, Safety
Engineer for Cotter Corporation, reporting -on the conference
betvreen representa~ives of Cotter Corporation and Nuclear
Engineering Company, during which the latter firm gave an
estimate of $2,000,000.00 for burial Of the \’Taste material at
the site owned by that firm in Illinois .
As Mr. ~1arcott advised, ‘I’Te are preparing to submit more
detailed lnformation to the Commission on the proposal for
burial at the present site i n HazehTOod, Missouri. \tfe will
furnish you with ·copies of further submissions and correspondence.
On behalf of Mr. Marcott, Cotter Corporation , and myself,
I wish to thank you for providing us with an opportunity to
discuss with you the problems and public policy issues t’lhich
surround our efforts to dispose of the waste mater1als safely
and quickly.
;z_::;rz ·-
Edward J. · ~ath Attorney for Cotter Corporation
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RocnV!LLE, HAn\’l.AND 2oaso
( 3 0 11 424-.. 707 –
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·. · ·April 2~, 1971
Jt.r. itobert E. Holl:tngm·rorth,
GGncrn l r-1anag0r’
United St aten At omic
Ener~y Commission
. lt.’a sh1ngton D.C. 205IJ5 ·
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Cotter- Corporation
Waste Disposal Project
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n~u~0<:1. upon tho facts a.nd c:trcums tnnce6 hereinafter set forth. Cotter Corporation hereby make~ application for author!ty. to d:tspo: 1e o f radloactiv~ 1·1aste matel .. inl de scribed belo\'1 'by depositing th ~ s.~mP. in the abandoned quart•y _ ut1.11zcd f.or eueh dtsposal on the property owned· and controlled by the . Atomic Energy Gommissi.on at ~·feldon Sp~ing~ Ntsaouri. Cotter Gorpor>at.ton, :tn 1967, ·purchased !’r0m a private .e.oncern ·
a substantial quo.nt 1ty of radioactive residues stored ·at · that time
at the ao called “airport site” 1n St. r~ouis, Misaoul’i for the pur- ·
pos e: of’ reproces sin.g that portion of the material wbich ~rns smenaolc
to treatment ‘in the ut”an1um mill· of: Cotter Corporation looatcd
ln Canon City, Colorado. · · .- – ·_ ,. ,·_
. – . . . .
The residues· ·purchased l-lere the product of earlier Commission
oper>a.t1ons, and represented a euhata.ntial problem at the time· when
they Nere acquired by Cotter Corporation; becauee the flrm which
purchneed them from the Commission and f”rom tth1ch Cotter Corpor- ·. –
· o.tion ~cqu1rec1 them had done ao speculatively, ‘<~Ti~hout ·e. program · f~r d1Gpoa1t1on, and subsequently terminated 1ts business act1v- -: it1ea. · ·· · · ' • . ,. ~ Incltt\.le. 1.rhc drums . are . :. _·
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Cotter Corporation, if autho~ized by the Commission to do so,
will transpo~t the drums by truck from Hazelwood, M1saour1 to the
qunrvy site at Noldon Spring (a distance or approximately thirty
{30) miles) and deposit them 1n the quarry, · aubjeot to Commission .
advice and direction, and at the expense of the corporation.
\ve believe deposit in th~ quarr’y’ to be the most sastiaractory
rc3olutiou or all substantial problems· involved in disposition of
the contarn1.nnten material. Among ·the factors \fhich dictate our
conclusion e.re ‘that the quarry site 1a utilized by the Commission
for. (1isposal of ~3 im:tlar contaminated material; -that no ~onflict
e;::tstrJ :ln this nituation ,,,ith the Comm1ae19n policy · aga~nst engag:
tn~ 1.n ope!’at:ions competitive \’lith private industry, since ~xist- ·
inF.; pl’ivately operated. ~oraste disposal ~ac111t1es are not · dee.lgned
in capacity oP other\lliae for disposition of material in -. the ~;\.iantity
and form involved in thia situation; that the distance to the
nearest comme:..–c :to.l disposal site, even \-‘Jere lt capable or handling
the material is two hundred (200) -miles as opposed to a · diatance
or thirty (30) miles from Hazelwood to \’Teldon Spring, and finally.
· the very sttbstantial difference in expense in dinpoaal other . than
at Weldon Spring quarry, even if ·such alternatives were otherwise
feaetb~.e. ·
vic request. the opportunity to present and discuss · thia prQ..:.
posal •tiith you and \’lith those of the Commiss:ton staff.’ . . concerned
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P R 0 P 0 S A L
Haze 1 \•Jood , · Missouri
AEC License #SUB 1022 (40-8025)
April, 1971
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noo coR<'NET cu11.0ING • ;:~5 soGrH. M·." n"M. .£c .~~v·e:uu" •sAINT LOUIS. Mlsso.oni 63105. . . . TI:t.Et'HONF.: (314) 06?.-342.~. ·.:. It is the intent of this proposal. to provide a ~ans \·1hereby th~ Latty Avenue Ore Storage Site may be deco.ntaminated and returned for normal -..,.....---------·-- ··--· land. use \·lith no restrictions on future u5e, in full compliance \'tith all ~~- -""""" . ' · ~ applicable rules and regulations of the Atomic Energy Commission • 2 . ·Figure 1 sho\'/s a schematic of the Storage Site \•lith the stockpiled mate· . rial outlined. This Jlk1terial has had·a long and varied history in re1at~on to its ultimate disposal as outline·d in your Commission's Invitation to · .B id No. AT-{23-2)-52, dated January 10, 1964; At that time a partial·.· · ' : ;· . . . listing of the material included: 74,000 tons of Belgian Congo Pitchb1end. · Raffinate containing about 113 tons of uranium, 32,500 tons of Colorado Raffinate containing about 48 tons of (iranium·and 8700 tons of leached Barium Sulfate containing 7 tons of uranium. Material indicated on· the schematic represents those listed above as purchased by Commercial Dis-. cou~t Corporation of Chicago, Illinois [License #S~1C-907 ( 40-7603 )] • · Since August, 1970, Cotter Corporation has be~n drying and shipping the Congo Raffinate to their site of operations in Canyon City, Colorado. (License No. SUB-1022 (40-8035)]. At the present time this operation is heing completed. L0\'1 concentrations of valuable metals and other elements have rendered the remaining material economi.cally unfeasible to process in like rM.nner. For this reason it is proposed to bury the remaining material on site. The landfill \•Jill be constructed in a series of excavations and burials. . . The area previously occupied. by the Congo Raffi nate \·Ji 11 be further exca- . vated, with the original uncontaminated earth stockpiled in a spoils. ar~a; to provide suffici~nt space for burial of the Colorado Raffinate. The area . . . . . . occupied by the Colorado Raffinate vli11 be made available for burial of .. the leached Barium Sulfate settling pond residue and other non-compressible contaminated material. . · l)il):r: / 1 ' ~;i:J:'(i~. fi~k::; Building "D", refer Figure 1, shall be thoro~ghly \\:;.:.i~ :;~ .~ ~. .: ~:<· J·.r~~--::~ ;::;,. ·~:: j:<• ~ ..= ·.: · .. :~ ~:.:~·.::”:~f:· ~.::·.:::; :. . :.:· ·;: .•: : ·. •. : · ·.::. ..: . ., . ·, :: .· •. ·•·· :. …., :.: :. • • .., · ·: .. !1~ • ……. ;..: ··-=-;.. •• .-.’: ·,.r~· .. , •. ._.:;,_ ,, •. ,. .. –<..- ¢. --·~ . ,. , from the site. Building "N', an office, 118", a garage and dining area, and· "C", an equiprrent storage area will not tequi re extensive decant amination .. Dirt, debris and other material deposited \•lithin Building "011 duti ng the drying operation VIi 11 be r!:moved and buried,. a long \~ith slightly contaminated original earth, on top of the Barium ·sulfate.· The top layer of earth on al1 contaminated areas \•Ji11 be removed and buried until radiation levels have been reduced to be1m·l AEC limits. · 3 Guidelines for the burial pits \•Jill .comply viith good engi~eering practices as \'tell as the rules and regulations of your Commission. A11 pits wi11 be of sufficient size to insure a m{nimum of four feet earth cover·. on the finished installation; All excavations will be sealed on the top and bottom with a four inch (4 11 ) thick asphaltic layer. If 11\•tet" conditions are ~ncountered while opening the pit, a11 sides \•till receive the asphaltic seal. All areas \•li11 be scraped c1ean· of contaminated earth sufficiently d~ep to insure a maximum gross radiation level of 0.05 mR/hr. The entir~ site \'Jill bQ graded to insure proper drainage \·lith no_ unsightl_y nXlunds or dcpressi ons. · It is the desire of Cotter Corporation to reutrn to its Lessor land which will in no \•Jay be 1 i mi ted in its useful ness or va 1 ue and \·till in no \'lay endanger the surrounding environment and its inhabitants. RETA-780 . •. . ... :. ·,·· RETA & 780 Latty Avenue c D CD Settling Ponds FIGURE 1 Sketch not to scale .. · . . . .' . . Colorado Raffi natc ·coTTER CORPORATION LATTY AVENUE STORAGE SITE H/\ZLENOOV, ~flSSOUR I - . ,• 4 :.: .· I ' . . '' ·- - · ·--.--· .. UNITED STATES ATOMIC ENERGY COMMISSION WASHINGTON, D.C. 2.0545 Hr . E. :· • ·’ ·••• ;’,\);:~X,; .\>U ,. ; :. i?.,;\i:J:;ii>:•.’fl’ “”‘·’~'(“~eJf,:%:o:.,~c’6 :;:: ” ;;, ., ., .• • .~’ ‘”” ·· <• ·"'~'' • • •·i' • · ·.' · ... ~(~:.2!;~~ UNITED STATES ATOMIC ENERGY COMMIS$lON WASHINGTON. D.C. 20545 I }.l (., June 28, 1971 J j.!pi r.:·~} r ~ ( ·. ~~ 1:. ~. =- ~ ·; "':"'! • I l . . I I ... ""'I ;. i I H<'·.< '7 . MEMORANDUN FOR THE F ILBS I •".!.~. . .. · ··· · ·· · · · ··· ·· · · , . I y_ .. I SUBJECT: MEETING \'liTH REPRESENTATIVbftOF':1COTTER. CORPORATION . ! . At the request of -Senator Peter Dominick (Colorado), Commissioner· Johnson met \>lith David Marcott, Executive
Vice President, and Ed\vard NcGrath, ~vashington Counsel,
for Cotte·r Corporation on June 2.4, 1971. Ot;hers
a~tending were Dr. Martin Biles and U. M. Staebler.
Messrs~ Marcott and McGrath had previously met with
personnel from the Division of Materials Licensing and
Wast~ and Scrap Nanageme_nt.
Cotter Corporation acquired radioactive residues from
early AEC milling operations Hhich had been moved from .
the St. Louis Airport to Hazelwood, a site in metropolitan
St. Louis, by a Baltimore Corporation which went bankrupt.
The material \·las acquired from Commercial Discount, the
fin.ancer of the orig.in~J. .p.urc.h?Js.c _fr.om the AEC. Selected
materials were sent to a plant .at Canyon City for recovery
of valuable minerals. Cotter has ~bout 15,000 tons of
materials to be disposed of in addition to about a thous and
.drums of contaminated materials which can be disposed of .
commercially at a reasonable cost.· They are committed
t o restore the property on ·which the material is stored
but have found that disposal on-site is not acceptable
under present r~gulations. The $150,000 they had allowed
for on-site disposal is to be compared with an estimate ·
of $2 million they have received from Nuclear Engineering
for commercial disposal at a site about 200 miles ar..;ay.
Mr . Marcott ·would Like to dispos~ of the material at the
quarry formerly usqd by the AEC near the St. Louis
operati.ons which is about -30 miles from the Hazelv10od
site. or: Biles reviewed the situation at the quarry,
concluding that disposal there would not be acceptable.
The basis for the estimate of $2 ~illion for disposal·
by Nuclear Engineering \-Tas not· knm’ln but it did not
seem consistent with the usual ~harge af ~bo~t-$0 .70
per cu.· ft. for commerciu.l disposa l _plus transportation.
(Separate information indicates this estimate may.include
decontamination of buildings at the site.) Dr.· Biles
suggested that ·transporting the material to Colorado
. ………. ·1
‘• ‘ , I
– 2 –
and adding it to ex~ sting piles of taili~gs there might
be worth exploring since the material .i s similar and.
would be quite small in quantity rela tiv~ t o these piles.
It was agreed that: . . · I .·
a) Both Cotter and AEC (Bi les ) \•lould look into
t he feas ibility of di~posal on other tailings
piles (i.ncluding licensing) .
b) Cotter t’lould provide a breakdown. of the $2
million estimate from Nuclear Engineering . . .
c) AE~ (Biles) would i nvestigate the. basis b?ing
used for private commercial disposal —
in particular whether pricing on ~ unit volume
basis ·was reasonable for this kind of ma~erial.
d) Cotter vlould provide a summary of the history
of the material and the contract obligations
rela~ive to ul timate disposal associated with
the various transfers . UO.l•~ l”‘~-~-J .. ~OJ.V .~ :~;:;.
· cc; General · Hanagcr
Dr. Martin Biles, OS
R. O’Neill, Cong. Rel.
H. Nowak, NSM
C .. H~nd~rs~n, DR
•2/, ) 7J .• ~b.£. 6./v’
U. M. Staebler
·-….. -.. – …….. _. ____ …… · ~ · · -· . …. , ..
ot J. T.~.·.


1967-08-15 – AEC – Historical Review of the Mallinckrodt Airport Cake

REPOSITORY–~~ ….. .._..~RCOLLECTION–_;.,;;.;;~—
NO. ~~-..:~~if–….-~—FO~
ER ~(JeJT~I?I. J uly 26 , 1973
0)4P371’E#~#stfl?~ Sr.~
Dr. !·lilllic.:m E. ! btt
Division of Envirorlirental Control
Department of I:nergy
:·7a.shingta1 D.C. 20543
Dear or. ; iott:
-‘IUL ltriP – l -r-
4114 C1oarU …. “·,…, ·- … (31C)m-12111
Da ppa, Wt- CSIJt
01., ….
Enclosed is a copy of a paper pre ,:Jared by an AJ:X:. offi cial
in 1967, entitled “liistori cal r-.eviev1 of t he i·!al linckrodt
r.J.rport Cake . :• T’nis i s t he only v.rri ttcn info:t:.mation r
have been able to find on any Uranium nd.l l tailings left
in St • .WOuis.
If you should f ind any other infoi111ation on this subject,
I v.ould u?preciate yarr sen.d ing zre a <::q)Y . ..:.:..c.. .:..::» 1 • .P le~e feel 5:-ee to contact ne i f I nay :.>e of f’ l'(the~
ass 1s tance to yoo. r- n
N C!2
Sincerely, co < m ;i 0 - n -1(..~< -F.' ::0 J0<:1v . . • i-at .• 0 ~islative Assistant THIS WfATION'i:IIY rlt1Nl1:0 ON P'AI'CJII MADII. ¥UTH " t:CVCL&D l'lftlla ... .. HISTORICAL REVIEH · OF THE 1-'.ALLINCKRODT AIRPORT CAKE 1~ - .,. _' .. .. . In discussing the history of t~e airport cake raffinates, it is t necessary to define t hem and this has been attempted by the _ :_ simplified f~owsheet given in Figure 1. Mos t of the pitchblende ·; ·p r ocessed by K2lli::1ckrodt was obtained as a concentrate from the ' Belgian Congo in 1944 and was shipped to St. Louis from the Congo in 55-gall on metal drums. The pitchblende was digested in 56 per cent nitric acid (93-102°C) followed by sulfuric acid to precipitate the lead and radium \llhen the ore had a low sulfate content. The precipitate was removed by a string-di scharge rotary vacuum filter and was usually leached with sodium carbonate to remove · residual uranium. The sulfate cake was stored in a separate location. since the Belgians (African Metals ) maintained ownership of · the radium. These residues are•presently stored at the Lake Ontario Ordnance works at Niagara Falls, New York. Some pitchblende was al so processed at Fernald and a similar cake, still stored in silos at National Lead Company in Cincinnati, is known · as Fernald•s K-65 residue . Barium carbonate s lurry was then added to the supernate to remove the excess sulfate . The barium sulfate cake was removed by a continuous solid-bowl centrifuge, leached with sodium carbonate, and also stored in a separate area. · The supernate was made 1 ~ in nitric acid and the uranium extracted with diethvl Pt~~~- : 7ne uranium was stripped from the ether with dilute; nitric acid. ' In the first extraction colu::m a precipitate for.::~ed 'Which was, on ·· · occasion, ~emoved by a Sperry Fil terpres s . The Sperry Cake wa_s __ · · : found to be a good source of protactinL9m-231 and .~u~)processed ~ ' about 20 tons ( about eighty 55-gallon drums) and obtained approximately ~wo grams of protactinium-231. The supernate from the .Sperry Press and the aqueous uranium tails were de-etherized and tr~at ed with a hydrated lime slurry . The s upe~ a te frcm a continuous rotary vacuum leaf filter was di s charg~d to the river, and the limed fraction becawe the airport cake . The cake, up until 1960, was about 25 feec hig~ . and covered three acres. ··•· . . ..... ; ... ~ Organic I i ! HN03 Strip ! Urani uin Product Figure 1 Pitchblende Conce:ltrate v . ·. HN03 Digestion ~. H2so4 ll • Supernate ~ sa++ t Supernate I (J D iethy I Ether ' b . Aqueous --- ~ Ume ! Aqt·-•·->’)\
/14 ·us
1, ;.oo
Ta”ble I
Uranium Conten::
.-2 • 192
Pitchblende Raffincte1
Colorado Raffinate
Ba3 S04 Cake (unleached)
Barium Cake (leached) ·
Miscellaneous Residues
1 Estimated to contain
1,775,000 pounds Cobalt
• 2,085,000 pounds Nickel
1,098,000 pounds Ccpper
The i:”:~ten!: ~f tbe s~q~~-~~–fqr … Sale~~ was. tQ. allow private industry
to recover r.he valuable meta1.s: copper, nickel, and. co bait. -The
original request:”for bid offered the bidder several alternatives.
The purchaser could use the existing site for purposes of conca~
tra~ing and extracting a~y d~sired material or he could remove.
t~e residue from the site for processing or utilization elsewhere.
Th.e materials remaining after the purchaser8 s processing operanons
were over could be–disposed Ol: oythepurchase:::-at:l:n~\·]eldon
Spri-ngsdump s1._t_e_wnether ·or rioE pro.cessing .. was·-aone-ontfie-prE:-sc?nt
site o~ elsewhere. The Weldon. Spring·s–Quarcy~Dump-s1te wss a’ pit: ‘~
located in·St. Charles County on Ydssouri State Highway No. 94
. approximately five miles southwest of the \ve ldon Springs plant ~d ~ ~
approximately 30 rni~es frcrn the ai~port site. The site wa~ssible
by truck f~om Missouri State Route 94 and a spur track lead·
off the existing east way of the Atomic Energy Commission’s plant
track system providing railway access to the dump pi·t.
– 4 –
In response to a ~equest in 1960, Mound made a cost estimate
based on a pro1uction rate of 1>000 grams of thorium-230 per year
·~ o\·~!7 a two to five-year period on the assumption the airport cake·
. i~ 3t. ~.ouis would be available. Pre.;urnably it may have been
I POE5ib!~ for Mound to obtain the thorium waste stream from the
1 private contractor hot~ever tha cost: estimate was based on start- :~ ,
‘ j
. ~
ir.g with unprc~~s~~d airport cake~ Inclu~ing manpower, shippi~g)
material, and arnortiza~ion of .c~piLal costs over a five-year
period, th~ estimated cosc of the thorium-230 was about $300 per
gram. At ~hat time, Mound was also instructed to make a survey
of all uranium mills in the country to determine if other potential
sources of thorium-230·existed ‘from which this amount of production
could be economically rnaint?ined. ?his survey is compiled in
MIJ1 .. l439, ~’Survey of Sources of Ionium, Thorium-230,~’ by P. E.
Figgins and H. W. Kirby •
Mound received word in September 1960 that the St~ Louis Area
Office was recommending that the bid be awarded to Contemporary
Metals; a company having a “portable processing plant.,. The AEC
talked with them about their probable process which was to be
‘:. car:ied oqt on site and it seemed that they were interested pri)
mar~ly in the cobalt and nickel. However, they also would have
!I’ a s~de st:ream. for co!’lc.entrating scandium and expected thorium to
. go 1.nto that stream.
. .
Later in 1960, word was received that it was quite unlikely that
tn~ private cont:rac~ would be awarded since the United States
~~ Geologic·al Survey forbid the clumping of the sludges, processed ·
:1 or not, into the quarries in question because of the high proba;
bjlity of contaminating’the Missouri River shortly above the
intak~s for the. St. Louis City and St. Louis County water supplies.
Due to the many· problems, the St. Louis Area Office was contacted
by_Oak.Ridge Operations and asked to hold up awarding any contract
:o~ airport sludge until the long range requirements for thorium-
230 could be fixed.

.i Ic is not clear exactly what transpired at this point (perhaps
;,·Conternporacy Hetals .bankrupted) since the material was subse-
. quently obtain~d by Co~~~~!l~_al !·~nin_g .. _and 1-A’d.ll~_I}.g _ of- Chicago
…. 5
· .. ..
£or $:26,000. Co~tine~~al borrowed $2~500~000 from Cc~~arcial
D,iscount of Chicago to buy ar.d p::oces-5-t:Ee-reiidu·e-s~–using the
riSidu:3 dS security. Concir.2ntal moved the macarial from the
l., i..,r… port t-.1:1 ~Q.th-=.r_si te in sp.”buroaQ.J1?z_glwoo..Q_. ‘!his mova required
ten dump trucks for five monch3 and co~t Continental $100,000.
they were unabl~ to maintai~ ~h~ loan paym~nts while they were
·. ~oving the materia:, so Caillffic~cia~ foreclosed tha loan • .. …
. fbe Commercial Discount Corp_Q_r_— Organic
HN03 Strip

Aqt:ecus to
Adjus~ Addity
10 Stage t-~idi-Mixcr
<1 ..J>-,.
Ac.u eous

10 Stage Midi-Mixer
Return to Airport·
– HN03
— 0 rg~~~. ~ Scrub
.. )
Aqueous Product
. !’
. ‘
… -·-~ ….
A flowsheet for -t-he-·-Femo:v:al.-.of-.o.the.r … than the thorium and uranium
has not be.en developed and th_is. now see&7ls. a reas_onable thing to
do at this poinc:-‘!Ite-n-or-f’i””f·te·en-drums· ·o£ this r.~c:terial wera
processed to develop a flm~sheet for- the recovery of the thoriur.1,
uranium, copper, nickel, cobalt, selenium, and a ~are earth fraction,
it-migh:. be: possible to raduce t.~e ::adioactive contamin£”t.ion
of the final W8Ste raffinates such that they would be no problem
and could be disposed of alrno·s·t anywhere.
The 250 kilograms of thorium-230 contained in these raffinates
are more interesting than ionium per se; cost estimates are already
in existence for irradiation to protactinium-231 and subsequent
irradiation to uranium-232. Mound has twelve thorium-230 slugs
on hand that were irradiated in the }ITR at Idaho Falls in 1960.
It· ·is planned to process these capsules in order to develop a flowsheet
for the production of protactinium-231 •

August: 15,. 1967
– 8 -.
l I
i t


2014-08-01 – EPA – USACE – Independent Technical Review for Operable Unit 1 at the West Lake Landfill Site

Independent Technical Review for Operable Unit 1 at the West Lake Landfill Site
The West Lake Landfill Site is on a parcel of approximately 200 acres located in
the northwestern portion of the St. Louis metropolitan area. It is situated approximately
one mile north of the intersection of Interstate 70 and Interstate 270 within the limits of
the city of Bridgeton in northwestern St. Louis County. The Missouri River lies about 1.5
miles to the north and west of the Site.
The Site consists of two radiologically contaminated landfill cells comprising
Operable Unit 1 (OU-1) and the Bridgeton Sanitary Landfill (Former Active Sanitary
Landfill) and several inactive areas with sanitary and demolition fill that have been
closed comprising OU-2. Land use at the site and the surrounding areas in Earth City is
Other facilities which are not subject to this response action are located on the
200-acre parcel including concrete and asphalt batch plants, a solid waste transfer station,
and an automobile repair shop.
The Site was used agriculturally until a limestone quarrying and crushing
operation began in 1939. The quarrying operation continued until 1988 and resulted in
two quarry pits. Beginning in the early 1950s, portions of the quarried areas and adjacent
areas were used for landfilling municipal solid waste (MSW), industrial solid wastes, and
construction/demolition debris. These operations were not subject to state permitting
because they occurred prior to the formation of the Missouri Department of Natural
Resources (MDNR) in 1974. Two landfill areas were radiologically contaminated in
1973 when they received soil mixed with leached barium sulfate residues.
The barium sulfate residues, containing traces of uranium, thorium, and their longlived
daughter products, were some of the uranium ore processing residues initially
stored by the Atomic Energy Commission (AEC) on a 21.7 acre tract ofland in a then
undeveloped area of north St. Louis County, now known as the St. Louis Airport Site
(SLAPS), which is part of the St. Louis Formerly Utilized Sites Remedial Action
Program managed by the U.S. Army Corps of Engineers (USACE)
In 1966, residues associated with the production and refining of uranium
materials were purchased by Continental Mining and Milling Company of Chicago,
removed from the SLAPS, and placed in storage at the Hazelwood Interim Storage Site
(HISS) on Latty Avenue under an AEC license. In 1967, Commercial Discount
Corporation, which obtained possession of the HISS property and residuals, began drying
residue and shipping them to Cotter Corporation in Canon City, Colorado (DOE 1987).
WLLFOIA4312- 001 – 0058946
In 1969, residues remaining at the HISS were sold to Cotter Corporation in Canon City.
In 1970, Cotter Corporation dried and shipped some of the remaining residues from the
HISS to Canon City (DOE 1994). In December 1970, an estimated 10,000 ton of
Colorado raffinate and 8,700 tons ofleached barium sulfate remained at the Latty
Avenue HISS.
Reportedly, 8,700 tons of leached barium sulfate residues were mixed with
approximately 39,000 tons of soil and then transported to the West Lake site in 1973.
According to the landfill operator, the soil was used as cover for municipal refuse in
routine landfill operations.
The geology of the landfill area consists of Paleozoic-age sedimentary rocks
overlying Pre-Cambrian-age igneous and metamorphic rocks. The Paleozoic bedrock is
overlain by unconsolidated alluvial and loess deposits of recent (Holocene) age. Alluvial
deposits of varying thickness are present beneath Areas 1 and 2. The landfill debris varies
in thickness from 5 to 56 feet in Areas 1 and 2, with an average thickness of
approximately 30 feet in Area 2. The underlying alluvium increases in thickness from
east to west beneath Area 1. The alluvial thickness beneath the southeastern portion of
Area 1 is less than 5 feet (bottom elevation of 420 ft/amsl) while the thickness along the
northwestern edge of Area 1 is approximately 80 feet (bottom elevation of 370 ft/amsl).
The thickness of the alluvial deposits beneath Area 2 is fairly uniform at approximately
100 feet (bottom elevations of 335 ft/amsl).
A subsurface oxidation event (SSE) is ongoing in the South Quarry Landfill
portion of the Bridgeton Sanitary Landfill. The South Quarry cell is connected to the
North Quarry cell which is adjacent to Operable Unit 1, Area 1, one of the locations on
site that received the radiologically contaminated soils in 1973. Pursuant to an order
from the Missouri Attorney General, the site owner is required to install a subsurface
barrier between the North Quarry cell and OU-1 Area 1 to prevent the SSE from
migrating into the radiologically contaminated materials.
As a follow-up to EPA R7 consultation with EPA’s National Remedy Review
Board (NRRB) in February 2012, the following evaluations are being conducted to assess
the Remedial Alternatives for OU-1: 1) partial excavation evaluation; 2) alternative
landfill cap designs; 3) evaluation on the use of waste treatment technologies, including
apatite; 4) recalculation of RIM volumes for a full excavation scenario; 5) groundwater
fate and transport modeling; and 6) recalculation of discount rate. These evaluations will
be contained in a forthcoming Supplemental Feasibility Study (SSFS) Amendment or
equivalent document.
WLLFOIA4312- 001 – 0058947
This will be an interagency agreement. The EPA is requesting assistance from
the US Army Corps of Engineers (US ACE) to conduct an Independent Technical Review
(ITR) of specific documents associated with Operable Unit-1 at the West Lake Landfill
and being developed in response to National Remedy Review Board (NRRB) comments.
The technical support may consist of performance of specific tasks which USEP A
contractors have neither the expertise or cannot provide at reasonable cost to EPA.
USACE shall furnish personnel and services required to conduct an ITR of
reports prepared by the Responsible Parties in response to the recommended NRRB
Tasks included in this scope are:
1. Project Planning and Support
2. Independent Technical Reviews
3. Community Relations Support
4. Close-Out
This task includes work efforts related to project initiation, management, and
support. Activities required under this task include the following, as applicable:
1.1 US ACE shall participate in a scoping meeting with EPA to discuss the work
1.2 USACE shall provide proposed level of effort and costs for the support activities
to be performed. Based on EPA’s review of the scope, level of effort and cost
estimate, USACE may be called upon to participate in negotiations with EPA on
the proposed level of effort and to revise the level of effort as a result of these
1.3 The USACE shall perform site-specific project management including:
1.3 .1 Establishment and maintenance of necessary work assignment files,
schedules, and project documentation
1.3.2 Provide monthly reporting and invoices. These documents shall contain
WLLFOIA4312- 001 – 0058948
narrative of specific task and subtask activities sufficient enough for the
EPA Remedial Project Manager (RPM) to evaluate the work assignment
1.3.3 Monitor costs and performance
1.3.4 Coordinate staffing and other support activities to perform the work
assignment tasks in accordance with the Statement of Work (SOW)
including USACE subcontractors, if utilized.
1.3.5 Attend necessary work assignment meetings
1.3 The USACE shall accommodate any external audit or review mechanism that
EPA may require. Level of effort for this work will be determined at a later date
and this IA will be amended to include this task and associated cost.
This task includes the work required to conduct the ITR and documents the
required deliverables.
2.1 US ACE shall coordinate and prepare a review plan and assist EPA in preparing
the reviewer’s charge statement.
2.2 US ACE shall perform an ITR of reports prepared by the Responsible Parties
(RPs) in response to the NRRB consultation with EPA on the Supplemental
Feasibility Study dated December 28, 2011. The purpose of the ITR is to
provide an independent assessment of the RP’ s work products to ensure the
scientific and technical components have been applied in a sound manner to meet
established regulatory requirements. The ITR will be conducted by qualified
individuals who are independent of those who performed the work, and who are
collectively equivalent in technical expertise (i.e., peers) to those who prepared
the reports.
The reports prepared in response to the NRBB recommendations will include:
2.2.1 Up to four ITR reports to address the following:
• The RP’ s evaluation of a partial excavation alternative;
• The RP’s recalculation of RIM volumes to address alternate excavation
• The RP’ s evaluation of up to three alternative landfill cap designs;
• The RP’ s evaluation on the use of up to five waste treatment technologies,
including apatite and soil sorting;
• The RP’s results of groundwater fate and transport modeling; and
• The RP’ s recalculation of all alternatives using a 7% discount rate.
2.2.2. A Supplemental Feasibility Study Addendum or equivalent document.
WLLFOIA4312- 001 – 0058949
2.2.3 A Revised Proposed Plan, if required. If a Revised Proposed Plan is
required, the level of effort for the ITR will be determined at a later date and this
IA will be amended to include this task and associated cost.
2.2.4 An Amended ROD, if required. If a Revised ROD is required, the level of
effort for the ITR will be determined at a later date and this IA will be amended
to include this task and associated cost.
2.3 USACE ITR team will review historical documents for familiarity and
understanding of the site. Historical documents will not be the subject of the
ITR. Historical documents to be reviewed include, but may not be limited to the
• OUI Site Characterization Summary Report
• OUI Remedial Investigation Report
• OUI Baseline Risk Assessment
• QUI Feasibility Study
• OUI Supplemental Feasibility Study
• OUI Record of Decision
• EPA Radiological and Infrared Survey Report (ASPECT) (May 20I3)
• MDNR Radiological Survey Report (May 20 I3)
• Radiation Management Corporation Radiological Survey (I982)
• NRC Radioactive Material in West Lake Landfill (I988)
2.4 US ACE shall prepare an ITR report for each of the documents reviewed. The
letter report will contain USACE’s technical evaluation and, to the extent
practicable, shall be written in terms understood by the general public. The letter
report will be submitted to EPA as a “final” product. The number of days
allotted for completion of the ITR will be jointly determined and agreed upon by
EPA and USACE based upon the size and nature of the document to be
reviewed, but shall be no less than 45 calendar days for any review.
2.5 The USACE ITR will focus exclusively on the scientific and technical aspects of
the documents and whether the scientific and technical components have been
applied in a sound manner to meet established regulatory requirements. It will
not address grammatical, editorial, or formatting aspects of the document.
2.6 The US ACE ITR team shall participate in one technical meeting with EPA and
the RPs for each of the documents reviewed. The purpose of these meetings will
be to provide clarification on any comments. These meetings will be conducted
in the St. Louis area. If not able to be accomplished via an in-person meeting,
the meeting shall be accomplished by phone and internet (Web Meeting).
2. 7 EPA shall furnish US ACE with the following:
WLLFOIA4312- 001 – 0058950
2.7.1 Background documents, data, and other information necessary to ensure
the ITR’ s completeness;
2.7.2 Notification, at least 30 days in advance, of submittal of a document for
2.7.3 A tentative schedule identifying anticipated document submittal dates,
review times, and meetings.
This task includes efforts related to community relations support to EPA.
Activities required under this task include the following:
3.1 Upon issuance of this IA, USACE shall attend two community meetings to inform
the public ofUSACE’s support to EPA under this IA and answer questions. For
the initial public meeting after IA release, USACE will prepare a Power Point
presentation or other visual aids, as required to communicate the ITR process to
the public. For the second public meeting after the IA release, USACE shall
attend to answer any remaining public questions regarding the IA scope.
3.2 Upon completion of the review of each document, US ACE staff shall attend a
community meeting and present a description of the work accomplished by
US ACE and the findings of the ITR. The presentation will be provided via Power
Point, or via other means, if required. An electronic file of the Power Point
presentation shall be furnished to EPA at the meeting. USACE shall furnish 50
paper copies of the PowerPoint presentation for distribution to the public.
3.3 USACE staff shall be available to participate in pre- and post-meeting public
availability sessions for the meetings at which the USACE reviews are presented.
USACE shall provide necessary public availability session displays and
information packets (up to 50 handouts of Power Point presentation).
3.4 EPA, as lead agency, shall be the central point of contact for all project
stakeholders. If requested by EPA, US ACE shall provide written responses to
written questions received by EPA from the community regarding USACE’s
scope of work for the ITR effort.
This task includes efforts related to work assignment close-out. Activities
required under this task include the following:
4.1 Upon notification by EPA, the USACE shall begin all internal procedures
necessary to close out the work assignment including any file duplication,
distribution, storage, or archiving per the contract requirements.
WLLFOIA4312- 001 – 0058951
4.2 The USACE shall return documents identified to EPA or other document
repositories as directed.
August 1, 2014 to December 30, 2016
The statutory authority for entering into this IA is Section 105(a)(4) of the
Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) of 1980 (42 U.S.C. 9601 et seq., Public Law 96-510, December 11,
1980), as amended by the Superfund Amendments and Reauthorization Act
(SARA) of 1986 (Public Law 99-499, October 17, 1986), and Executive Order
1.3.2 Monthly Reports/Invoices
2.2 ITR Reports
Project Manager Dan Gravatt
Project Officer Ina Square
Throughout period
Per agreed upon schedule
WLLFOIA4312- 001 – 0058952

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