1980-11-17 – MDNR – West Lake Landfill – Reason for contamination in northermost area of West Lake Landfill unknown at this time



1976-06-02 – MDNR – West Lake Landfill – Letter from Director Karch to NRC after Post-Dispatch Series

missouri department of natural resources
P.O. »•« 1368 J.«l.f.»n City. Mifiowfi 65101 314/751-2815
June 2, 1976
Mr. James G. Keppler
Regional Director
U.S. Nuclear Regulatory Commission
799 Roosevelt Road
Glen Ellyn, IL 60137
Dear Mr. Keppler:
In articles published May 30 and June 1 (copies enclosed) St. Louis
Post-Dispatch reporter Margaret W. Freivogel presented evidence that
some seven tons of uranium were dumped in 1973 at the West Lake Landfill
in St. Louis County by an Atomic Energy Corjnission subcontractor
removing radioactive waste material fror. a site in Hazelwood, Missouri,
The area was closed as an industrial and sanitary landfill by this
Department in 1974 (a new sanitary landfill in an adjacent area protected
from groundwater contact now operates under DNR permit). The
closed area where the dumping allegedly occurred may be in direct
contact with groundwater. It has no monitoring wells to permit
evaluation of groundwater contamination.
In your letter to me of February 19, 1976 you stated that “a review by
the then AEC showed there was no significant health or environmental
hazard associated with the burial”. The letter to Cotter Corporation
from John G. Davis you enclosed stated, “It is our understanding from
your contractor that the material was then deposited under about
100 feet of refuse and earth at St. Louis County sanitary landfill
No. 1.” The investigation by the Post-Dispatch indicates that AEC_did
not know the correct location of the dumping, the local geology, nor
the actual concentration of uranium dumped. The depth cited must
also be incorrect since no landfills in the St. Louis area contain
100 feet of fill. I must therefore question the validity of the AEC
“review” of the burial operation.
I respectfully request that in view of the concerns of this Department
and the people of the St. Louis area, that the Nuclear Regulatory
Commission takes steps to:
1. Provide me with all documents which might assist me in verifying
the Post-Dispatch report, and in establishing the exact amount
and chemical form of radioactive materials allegedly dumped at
Vest Lake.
Exhibit A
1 of 4
Mr. Kcpplcr
Page 2
June 2, 1976
2. Require the Energy Research and Development Administration,
as successor to AEC’s source material operations, to
a) Include the West Lake Landfill in the areas it has selected
for intensive aerial and ground level radiation monitoring.
b) Locate the uranium precisely within the landfill, both as
to position and depth.
c) Install appropriate groundwater monitoring wells and implement
a monitoring program to determine the extent, if any, of
groundwater contamination.
d) Recommend actions to be taken to protect landfill workers
and the public from any potential hazards associated with
this material.
3. a) Advise •£ on who would be liable in the event that cleanup
costs are involved.
b) Ascertain whether federal laws or regulations were violated
by either the Atomic Energy Commission or its subcontractor
in the disposal of source material at an unlicensed site.
In a related matter, I was disappointed to learn that you do not maintain
records of radioactive waste burials carried out by licensees under
authority of Section 20.304 of Title 10 CFR. I hereby respectfully
request that your office obtain such records from all Missouri licensees
who have made such burials and make these records available to me.
Kenneth M.
Division of Environmental Quality
cc: Robert J. Koke, EPA Region VII
Exhibit A
2 of k


1972-10 – Cotter Corporation Contract with B&K Construction

THIS AGREEMENT, made and entered into as of this
day of October, 1972, by and between COTTER CORPORATION, a New
Mexico corporation (“Cotter”) and B & K CONSTRUCTION COMPANY,
INC., a Missouri corporation (“B & K”) ;
WHEREAS, Cotter owns an amount of mineral residue
(the “Mineral Residue”) stockpiled at 9200 Latty Avenue,
Hazelwood, Missouri (the “Plant”), and
WHEREAS, Cotter and B & K desire to contract with’
regard to moving the Mineral Residue from the Plant and
restoration of the surface area of the Plant after such removal, and
WHEREAS, because much of the Mineral Residue consists
of radioactive materials, moving the same and restoration of
the Plant after removal may only be done under license (the
“License”) from the United States Atomic Energy Commission (the
“AEC”), and
WHEREAS, Ryckman, Edgerley, Tomlinson & Associates,
Inc. (“RETA”) consulting environmental engineers has, on
behalf of Cotter, applied to AEC for a License, such application
being in the form of .a “Proposal for Decontamination of Latty
Avenue Storage Site, Hazelwood, Missouri” (the “Proposal”),
a copy of which is attached hereto as Exhibit A,
NOW, THEREFORE, Cotter and B & K agree as follows: SE
1. As hereinafter used, the term “Work” shall
include all labor and the furnishing of any equipment, material, ~
COT 00^0
supervision or advice necessary to perform the tasks described
herein and in the Proposal and the License.
2. All Work shall be performed strictly in accordance
with the Proposal and the License and under the supervision of
RETA, although such supervision by RETA shall not alter the
status of B & K as an independent contractor.
3. The Work shall consist of three categories,
which categories and the compensation to be paid B & K for each
are as follows:
a) Hauling of Radioactive Mineral Residue — the
cost of hauling and dumping all radioactive Mineral Residue
(including contaminated topsoil) at the Weldon Springs
dispoal area shall be $3.25 per ton.
b) Loading and Shipment of Mineral Residue — the
cost of loading Mineral Residue on rail cars for shipment
shall be:
i) Per ton, $1.80 until 7500 tons have been
loaded and shipped and thereafter
ii) Per ton, 80£ for the balance.
•All shipments shall be C.O.D. Cotter’s siding, Canyon City,
c) Surface Restoration— any necessary surface
restoration and backfil will be compensated for by the ^
prices for the rest of the Work except that D & K shall ra.
be paid $1.85 per ton for procuring and dumping topsoil
if the stockpile of topsoil at the Plant is insufficient
for the purpose. 7
4. B & K agrees, if requested by Cotter/ to perform
any other jobs (“Additional Work”) requested by Cotter or
RETA which may. be necessary to restore the Plant as required
by the Proposal or the License and any such Additional Work
shall be compensated for on the basis of the cost thereof to
B & K plus a fee of 20%.
1. Cotter agrees, upon the execution and delivery
hereof, to advance B & K the sum of $10,000 (the “Advance”)
which amount will be in trust for application against costs
accruing to B & K in performance of the Work.
2. B & K will arrange for the renting of a scale
to be used at the Plant for the weighing of Mineral Residue
to be dumped at the Weldon Springs disposal area and for the
weighing of any topsoil to be dumped at the Plant by B & K.
The cost of use of the scale shall not exceed 2jzf per ton and
shall be paid by Cbtter.
3. B & K will arrange for the attendance of a bonded
and qualified scale operator to operate the scale at the Plant.
The cost of the scale operator shall be paid by B & K.
4. Not more frequently than weekly, B & K shall
draw on the Advance for the number of tons of Mineral Residue
or topsoil hauled, loaded, shipped or procured and dumped, as
the case may be. The amount of each draw shall be at the rate
specified in Article II of this Agreement for the number of
tons hauled or procured as reflected by weight tickets issued
by the scale operator at the Plant or by the railroad carrying
Mineral Residue. No part of the Advance shall be applied to
the cost of Additional Work.
5. Contemporaneously with each draw, B & K will
forward all weight tickets vouching for the amount of the draw
to Cotter. Cotter will, after verifying the amount of the
draw vouchered, reimburse B & K for 90% of the draw except
that, when RETA certifies that 85% of the Work has been done,
the retained amount of each reimbursement shall be reduced to 5%.
6. When B & K determines that the Work is substantially
complete, it shall prepare and submit to RETA a list of remaining
tasks to be performed. Upon certification by RETA to Cotter
of the accuracy of B & K’s representation of substantial
completion, Cotter shall pay B & K an amount which, when
aggregated with all payments previously made to B & K, shall
equal 95% of the aggregate of all draws approved by Cotter for
7. Upon certification by RETA that the Work has
been completed, Cotter shall make final payment to B & K, such
final payment to include all retained amounts. If the final
payment due is less than the amount then remaining in the Advance
account, B & K will reimburse Cotter accordingly.
1. B & K will, during the effectiveness of this
Agreement, carry adequate insurance for workmen’s compensation,
2E disability, employee bodily injury, occupational sickness or i—
disease, personal injuries and property insurance in addition to
any insurance required by the Proposal and the License.
2. Cotter will maintain its own liability insurance ^
to protect it against claims arising from operations under this
Agreement and property insurance covering the Plant.
1. The following, in addition to any other occurrence
which may, according to law, be a default hereunder, shall
severally be termed events of default (or an “Event of Default”):
a) If B & K does not proceed diligently with
the Work.
b) If the Work does not conform with the
requirements of the Proposal and the License.
c) If B & K files or suffers to be filed a
petition in bankruptcy or makes a general assignment
for the benefit of its creditors or suffers the appointment
of a receiver for all or any part of its property.
d) If B & K fails or refuses to make prompt
payment to any subcontractors, laborers or materialmen.
e) If the Work is stopped for a period
exceeding 30 days by an order of any court or administrative
agency of competent jurisdiction.
2. Upon the occurrence of any Event of Default as
that term is hereinabove defined, Cotter may order the Work
stopped whereupon B & K will cease performance and will remove
all of its property and equipment from the Plant. Cotter
shall thereupon have the right to complete performance of
the Work, or to arrange with another contractor for completion SE
of the Work. Retainage amounts shall be applied against the xs
cost of completing the Work to the extent that such costs
exceeds costs herein specified and B & K shall remain liable (_>en
for any damages attributable to its default. rva
1. B & K shall be responsible for maintaining and
supervising all safety precautions and programs in connection
with the Work, particularly those precautions and programs
specified by the Proposal and License.
2. In the event, during performance of the
Work, any changes in the Proposal or the License should occasion
an adjustment in costs apecified in Article I hereof, Cotter
and B & K agree to negotiate an adjustment in costs in good faith.
Whether or not a change in the Proposal or License occasions a
change in costs shall be determined by RETA. No change in costs
shall be made and all Work shall be performed at the costs
specified in Article I hereof unless Cotter and B & K have
previously agreed upon an adjustment.
3. B & K agrees to protect, indemnify and hold
Cotter harmless against all claims, damages, losses and expenses
(including attorney’s fees) arising out of or resulting from
performance of the Work but only to the extent that any such
claim, damage, loss or expense is attributable to:
a) Bodily injury, sickness, disease or
death, or injury to or destruction of property.
b) A negligent act or omission of B & K

or any of its subcontractors, agents and employees.
gtlg However, this indemnification shall not extend to any occasion p
JCa otherwise indemnified against to the extent such claim, damage,
loss or expense is attributable to actions taken by B & K in
accordance with the Proposal, the License, or instructions of <^ en Cotter or RETA provided that such is. the primary cause of the Co injury or damage. .;.-•... .. .. x -4» This Agreement shall be-governed-by the law. • •• .. - of the State of Missouri in all respects. 5. This Agreement shall not be assigned without the written consent of both parties hereto and Cotter shall have no obligation to recognize any assignment of any invoice or payment hereunder due from Cotter to B & K. 6. The rights and remedies specified herein shall be in addition to and not a limitation of any duties, obligations, rights and remedies otherwise available in law or at equity. 7. Cotter shall furnish or cause to be furnished at the Plant the railroad cars required for loading of the Mineral Residue in accordance with a railcar schedule requested by B & K. 8. If required by the terms of the License or the Proposal, security guards shall be furnished by Cotter at Cotter's expense. 9. Any notices required or given in connection with this Agreement shall be valid and sufficiently made and given if mailed, postage prepaid as follows: To B & K, Attention: Robert S. Davis, Jr., Vice President 4140 Cypress Road St. Ann, Missouri 63074 To Cotter, Attention: Mr. David Marcott Box 751 Canyon City, Colorado 81212 Copies of any notices given hereunder shall also be given to s: Ryckman, Edgerley, Tomlinson & Associates, Inc., Attention: Mr. ' Phillip K. Feeney, Project Manager, 12161 Lackland Road, St. Louis, Missouri 63141. _ CjJ 10. If either party is unable, wholly or in part, en -=~ to carry out its obligations under this Agreement by Force Majure, -7- the party so unable to perform shall give the other party prompt written notice with a statement of the reasons why performance is impossible. Notwithstanding anything herein to the contrary, this Agreement shall not thereupon be terminated but the obligations of the party asserting the Force Majure, insofar as effected by the Force Majure, shall be suspended during the continuance thereof and so long as the party asserting Force Majure diligently seeks to correct the conditions making performance impossible. The term "Force Majure" as used herein, shall mean an act of God, strike, lockout or other industrial disturbance, act of the public enemy, blockade, riot, lightning, fire, storms, flood, explosion, governmental restraint, action by the United States Government through the AEC or any other agency regulating or interfering in any way with any of the parties' rights and obligations under this Agreement and any other cause whether of the kind specifically enumerated above or otherwise which is not reasonably under the control of the parties. IN WITNESS WHEREOF, this Agreement has been executed as of the day and year first above written. B & K CONSTRUCTION COMPANY, INC. Bv: '£-**> ^


2012-01-10 – Monthly Status Report – December 2011 West Lake Landfill Operable Unit 1, Bridgeton, Missouri


7220 West Jefferson Avenue, Suite 406 telephone (303) 940-3426 Lakewood, CO 80235 Telecopier (303) 940-3422
January 10, 2012 VIA: Electronic Mail
U.S. Environmental Protection Agency Region Vll 901 N.S”^ Street Kansas City, KS 66101
ATTENTION: Mr. Dan Gravatt
SUBJECT: Monthly Status Report – December 2011 West Lake Landfill Operable Unit 1, Bridgeton, Missouri
Dear Mr. Gravatt,
On behalf of Cotter Corporation (N.S.L.), Laidlaw Waste Systems (Bridgeton), Jnc, Rock Road Industries, Inc., and the United Sates Department of Energy (the “Respondents”), Engineering Management Support Inc. (EMSI) submits the attached status report for the month of December 2011 as required by paragraph 56 ofthe West Lake Landfill Administrative Order on Consent, Docket No. VII-93-F-005. Ifyou have any questions or desire additional information related to this status report or any other aspect ofthe project, please do not hesitate to contact me.

Paul V. Rosasco, Distribution:
Shawn Muenks – Missouri Dept of Natural Resources
Victoria Warren – Allied Waste Industries, Inc.
Ward Herst – Herst & Associates, Inc.
Jessie Merrigan – Lathrop & Gage
Bill Beck – Lathrop & Gage
Charlotte Neitzel – Holme Roberts & Owen
Steve Golian – U. S. Department ofEnergy
Steven Miller – U. S. Department ofEnergy (via electronic mail)
Christina Richmond – U.S. Department of Justice (via electronic mail)
Dan Feezor – Feezor Engineering
Mike Bollenbacher – Auxier & Associates

Monthly Status Report – December 2011
West Lake Landfill Operable Unit 1
Bridgeton, Missouri

This status report has been prepared by Engineering Management Support Inc. (EMSI) on behalf of Cotter Corporation (N.S.L.), Bridgeton Landfill, LLC (formerly known as Laidlaw Waste Systems [Bridgeton] Inc.), Rock Road Industries, Inc., and the United States Department ofEnergy (the “Respondents”) for Operable Unit -1 (OU-1) at the West Lake Landfill as required by paragraph 56 ofthe West Lake Landfill Administrative Order on Consent, Docket No. VII-93-F-005.
1. Work Performed During December 2011
Proiect Planning
A final Work Plan for preparation of a Supplemental Feasibility Study (SFS) of “complete rad removal” altematives addressing EPA and MDNR comments was submitted to EPA and MDNR on June 7, 2010.
Note – A draft Remedial Design Work Plan was submitted to EPA in November 2008. In accordance with direction from EPA, all work on design ofthe ROD-selected remedy has been put on hold until after completion ofthe SFS evaluations of “complete rad removal” altematives.
Fieldwork – Sample Collection/Analysis
Report Preparation
A revised SFS report was completed and submitted to EPA and MDNR on September 30, 2011. The Respondents received comments from EPA on November 14, 2011. EMSI received comments from MDNR on November 21, 2011: EPA provided guidance relative to MDNR comments via e-mail on December 7, 2011 and via U.S. Mail on December 9, 2011. Work was performed during December to address EPA and MDNR comments and prepare a final version ofthe SFS report. The revised SFS report was submitted to EPA and.MNDR on December 16, 2011. A revised title page and revised ” compact disks without the Executive Summary were submitted on December 28, 2011. An Executive Summary was submitted separately on December 29, 2011.
The monthly progress report for November 2011 was prepared and submitted to EPA and MDNR on December 10, 2011.
December 2011 Projeci Status Report Westl..ake Landfill ou-1
I/I0/I2 Page 1
Proiect Management

Analytical Data Collected During This Reporting Period None.

Work Scheduled to be Performed during January and February 2012

With completion ofthe revised SFS report in December 2011, no further work on the SFS or any other aspect ofthe project is anticipated to be conducted during January or February 2012 unless additional work is requested by EPA. Per prior direction from EPA, all work towards finalizing the Remedial Design Work Plan and implementation of the remedial design activities is on hold until the SFS is completed.

Problems Encountered None.

December 2011 Project Status Report West Lake Landfill OU-1
Page 2


1988-02-17 – NRC – General Counsel recommendations of legal resources available to properly dispose of West Lake Landfill wastes

1 ” 1983
MEMORANDUM FOR: Richard E. Cunningham, Director
Division of Industrial and Medical Nuclear Safety
Office of Nuclear Material Safety & Safeguards
FROM: Stuart A. Treby, Assistant General Counsel for
Rulemaking £ Fuel Cycle,
Office of the General Counsel
In your memorandum of January 29, 1988 you requested advice as to the
legal resources avai.lable to the NRC to require a. former licensee, the Cotter
Corporation, to properly dispose of radioactive wastes dumped In the West
Lake landfill on the outskirts of St. Louis, Missouri.
The background information accompanying your memorandum shows that the
radioactive material, seven tons of uranium, was contained in some 8700 tons
of barium sulfate mixed with about 39,000 tons of soil. It was moved to the
landfill between July and October 1973 from the Latty Avenue site which had
been used by the licensee to dewater uranium processing residuals purchased
from the AEC prior to shipment to the licensee’s uranium processing mill at
Canon City, Colorado, for further processing. The operations at Latty
Avenue were carried out under a source material license, SUB-1022, which
was subsequently terminated. It is also abundantly clear that the AEC was
fully aware in 1974 of the admixture of the barium sulfate with soil and its
transfer to the landfill. See letter of November 1, 1974 from John G. Davis,
Deputy Director for Field Operations, Directorate of Regulatory Operations,
to Cotter Corporation.
Mr. Davis1 letter noted that, “The disposal does not appear to be within the
intent of the Commission’s regulations, 10 CFR Part 40, to allow alteration of
the physical nature of Source Material (i.e., dilution of solids with
nonradioactive source material) in order to obtain a physical mixture which
would no longer be subjected to licensing by the Commission.” An inspection
report, No. 040-8035/74-01, transmitted on May 17, 1974 identified the same
transfer of material to the landfill as a disposal contrary to the requirements
of 10 CFR 20.301. There does not appear to have been any follow up
enforcement action by either the AEC or the NRC to these two apparent
violations of regulations.
It is a foregone conclusion that the usual enforcement procedures of the
NRC, that is, a notice of violation or order to show cause leading eventually
to a civil penalty, would be of no avail in this case. In Secy-85-285 the
General Counsel and the Executive Director of Operations (for the Executive
Legal Director) provided a legal analysis of the application of 28 U. S. C.
2462, a federal statute of limitations, to enforcement action of the NRC. The
– 2 –
conclusions of that legal analysis, when applied to the facts of this case,
clearly Indicate that any administrative enforcement action that could or
would result in a civil fine, penalty or forfeiture, is barred by the five year
limitation on actions In that statute. The five year period commences to run
from the time of the violation. In this case that is October 1973, at the
latest. Accordingly, normal enforcement action by the NRC leading to civil
penalty would have been barred after the end of October 1978.
The only effective resource available to NRC at this point in time would be
judicial action under Section 232 of the Atomic Energy Act of 1954, as
amended. Section 232 authorizes the NRC, through the Attorney General, to
seek injunctive relief with respect to violations of regulations or orders.
This would, of course, draw into question whether an order to clean up the
landfill (if that action were to be selected to establish a basis for injunctive
relief) was lawful, as well as if the other necessary bases for injunctive
relief were met, for example, that no other remedy was available, and that
the health and safety hazard warranted judicial intervention. The question
of the lawfulness of the order would likely turn upon the question of
whether there was indeed a violation of regulations in sending the material to
the landfill. Whether there was a violation of 10 CFR 20.301, as stated In
the inspection report, depends upon how 10 CFR 40.13(a) is construed. We
note that there is nothing in that section or elsewhere in 10 CFR Part 40
that expressly prohibits dilution of source material in a mixture to below .05
weight percent in order for it to be exempted from the regulations In Part
40. If exempt, the requirement for transfer to an authorized recipient
would not apply. (See attached memorandum from W. Olmstead to J.
Lieberman) Thus, the licensee could argue that the dilution with soil was
legal and that the transfer and subsequent disposal were legal.
Although the doctrine of laches (a doctrine of repose applied in equity
cases, such as injunction proceedings, analogous to a statute of limitations)
does not apply to the United States Government, the fact that 14 years has
elapsed since the AEC/NRC had evidence of the disposal, and had considered
it a possible violation, argues against the need for immediate vigorous
enforcement through a judicial injunction. Added to this is the fact that the
AEC/NRC terminated the license with full knowedge of the disposal. One
could argue that the responsible regulatory agency, in terminating the
license without further enforcement action, haa determined that the alleged
violations were without merit. Finally, the United States has an alternative
The interpretative problems associated with 10 CFR 40.13(a) are
severe. We have not been able to find anything in its rulemaking history to
support a conclusion that it prohibits dilution, or that it is strictly limited to
chemical mixtures, solutions, alloys, or compounds, under a restrictive
definition of chemical. For example, chemical solutions, compounds, mixtures
and alloys could arguably be limited to those produced by or used in a
chemical process. Thus, the barium sulfate plus uranium would be a
chemcial mixture, but separated uranium subsequently admixed with ordinary
soil would not.
– 3 –
statutory remedy. Uranium is a hazardous substance under CERCLA
(Superfund) and the response authority under Section 104 of that Act could
be invoked.
If the staff determines upon proceeding judicially. Section 161c of the Atomic
Energy Act would authorize the NRC to conduct the necessary studies and
evaluations to support any order to be issued and any subsequent request
for enforcement of the order by judicial injunction. If EPA was to be
requested to proceed under Section 104 of CERCLA then EPA would initiate
the necessary studies and evaluations and supervise the remedial action. We
note that under CERCLA, EPA is not required to litigate responsibility
before proceeding. Under CERCLA, litigation comes after the fact and is
focused upon collection of agency remedial action costs and penalties
from responsible parties.
Stuart A. Treby, Assistant General
Counsel for Rulemaking 6 Fuel
Office of the General Counsel
As stated


1988-01-29 – NRC Memorandum – West Lake Landfill Actions

Hugh L. Thompson, Jr., Director
Office of Nuclear Material Safety
and Safeguards
Richard E. Cunningham, Director
Division of Industrial and
Medical Nuclear Safety, NMSS
A Draft Summary Report on
Landfill has been prepared
investigations of the site
Resources information. We
action is called for, but
are necessary to determine
determine who should be re
remedial action.
the uranium ore processing wastes in the West Lake
based on reports from NRC contractor field
NRC records and Missouri Department of Natural
have concluded from this review that remedial
that further technical information and evaluations
how it should be accomplished. We also need to
sponsible for conducting the necessary studies and
As we discussed with you, we are asking GC to determine what legal recourse we
have with the former licensee, the Cotter Corporation, with respect to actions
required at the landfill. Failing any recourse through Cotter, our next step
will be to request EPA to take action under its Superfund program.
Copies of our memorandum to Stuart Treby, GC, and the draft report are enclosed
for your information. We will keep you informed of our progress on this matter.
Original signed By i
Richard E. Cunningham, Director
Division of Industrial and
Material Nuclear Safety, NMSS
Enclosure: As stated
Distribution vj\ c
Docket #40-8801
IMNS Central File
NRC File Center
DATE:1/1^/88: 1 8:


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;


1976-10-20 – AEC – Supplemental Report – Investigation for Uranium-Thorium Cotter Corporation, Latty Avenue Site, St Louis Missouri

… .
OCTOnER 20, 1976
“Pursuant to the oncoing investigation of possible uranium/thorium
contamination at the Latty Avenue site, Mer.~1~. J. A. Pagliaro and
a. T. Gibson performed a site inspection Oll Octoher 20, 1976. The
pu~~osc of this inspection vas to identify tha property owner from
·county tax records, to surv~y the proparty with bct~-gamma nnd
.alphn survey instrumentation, and to obtain selected soil and
·vegetation samples for laboratory analy~cs.
The records revie~oTed at the St. Louis County Building, 41 South
Central.. St. Louis, Missouri, were the current county prop~rty tax
rolls. County parsonnel stated the tax recorcs cxnmined were
dated as of July 1976. The record indicated the followin~:
Address~ 9200 J..atty Avenue
Commercial Disco:.mt C~rporation
SS East Hom:oe StrcC!t
Chicazo, Illinoi~ 6~601
3.5 acres
._ ….
Telephone communica:ion with IE:III was performed to ascertain
whether the pr_opcrLy had since been transferred. A~dition:tl
information w~s received ubich indicated Co~r. “. D.crcinl Discount
Corporation had tr.:nsfcrred c\-mcrship of the prop~rty in August 1976
to the Bayless Company, 175 Outer Road t-lest, Valley rark, Mitu;ouri.
A site invcstig:ltion was then performed and ~amplcs were obtoineci.
Figure 1 indicat~s the relative position of various buildings,
landmarkr., and loccltions of collected samples. The arc~ in Fi.c;urc 1
encompassin~ the ~bandoncd garace. abandoated warehouse building,
and the abandor.ed and boarded-up burned building w:ts estimated to be
approximatcly”thr.ec ())·acres. The entire area, in~luding the
varebouse area nr:J plowed field, \.”as e~timatcd to be in excess


1972-12-05 – Cotter Corporation – Decontamination of Latty Avenue Storage Site, Hazelwood Missouri

n’ … __ …- ·’
WLA 2154
=··- ‘”:’l : “‘” ·- ~.
; ~ : .. ; f • .'”!;. ( _.
:.;..,: . .. =~-;”‘·:- …
tr. Frar~< ?it~nan, Pirec~or Divisic:~ cf W ~t:.a i-;ar.age~;ot: and Trans~or~ati~;o U.S. Ato::tic En\;r~y Ccr=.ission WashinEt~n, D.C. 205~5 Dece10e.r S, 1!:7 . Re: Cot:t:e~ Cor?cration-Decontaminat:ion of Storaz.a Si :-s, ~a::el""·ood, Hi..ssot.:ri Cott:c~ Cor~c~a~ion sub~its he~~with a orc~csa: fo~ ceco:1t:~=.ina~i~~ cf th~ si~ a a~ Lat:~y Avar.ue, fiez~ l\,oc::!, l·:.izso~=-i u;c::1 ·~~.:.c:t ce!'~clin r-z:.~ioac-:.i•Je r~si·.!ue~ cic:--ivad fror:: t: ite prccessi::~ of Co;;;.:o m"'a!"•i u::-. o:-cz have been store!oration al’.d 5 & :…
Const~c~ion Coo~a~y, !nc. 7 which set fo~h L~ de~ail~
the ~:u,e~ in wale~ t~e deconta~~tion orocess will
be ef!ec:tec. –
As ycu and your s~aff ~iow, Cot~er Cor?ora~io»
a~quireci tr.e residue cat:eri~l ~, lS67, and in ~h~
in~eri~, r~:ov~~,;rocessed and ~de ult~ate dispcsi~
ic~ of all resi~ues ~hich coulc eco~o:ically
be ~rea~~d except for 1:,uoo “tens oi Colcraco
raf£~ia-:=~ ~~ic~ ~i~l be shi?P=~ to the ~ll L~ ~t~
~ •
WLA 2155
near future. The then re::naining ::.a:tarial, which is
t~e subject of this proposal, consis~s prir.cipally
of leae~ec bari~ sulfate, niseellar.eous residues
and da~ris, cocprising approximately a,soo tons.
We have ex~lored all altar~a~iv~s to dis~ositicn
at the Quarry DUr.p Site ~~d conclude tha~ none of the~
offer comparable advantages in terms of safety, convenience
and econo~cs. The Quarry Dump Site alreaay
contains similar raaioactive waste and must be consi~eraa
a permanent burial area, and its location in relation
to the Hazelwood stcrage site L~sures safe transpor~atic~
ove~ a distance ma~y ti~es shorter than the nearest
available alterna~ive.
We stand ready tc provi~a any !frr~her inforr~tiov
which you ~1 dasire i~ considering ~~d a~ting upon ‘
this proposal.
Ve~y truly yours,
By: ~a-.:J p. m ~·:ZI–
oav~c:; ?. ,.a;::-co”C~,
txecu~ive Vice Presidan~
WLA 2104
‘\.., .. ,..·
,_.. ..
AEC License No. SUB 1022 (40-8025)
May, 1972
-., ~ …
~ .. .
.. .. –
rt is the intent of this proposal to provide a
means whereby land leased by Cotter Corporaticn of Golden,
Colorado (t~e Licensee} may be decontaminated and returned
for•no~al ~and use with no restrictions, in full compliance
with all applicable rules a..11d regulations of the Atomic
Energy Co~ssion. The property in question consists of
Hazelwood, Missouri {see FI~J?~ 1).
D~~ recent years, the area has been use~ as a
.. storage and processing site for raffinates and c~~er radioactive
res~dttes, and other radioactive debris. This proposal
presents a plan of action for decontamination of the site and
ultimate disposal of the radioactive residues and debris •

–· RETA &
Latty Avenue
Sketch net to scale
WLA 2106
WLA 2107
The history of the residues is a long and complicated
one. The most complete historical review of this
material was compiled by Walter J. Raubach in August, 1967.
This review is included hereLn as APP~~~IX A.
According to Mr. Bauback, the original material
was obtained from the Belgian congo in 1944 for processing
by_Mallinckrodt at the Destrehan Street Plant in St. Louis.
acre trac~, located at Roberston, Missouri. In J~~e of 1960
the residues were offered for public sale for processing or
utilizaticr. by private industry.
•T.he intent of the ‘Offer for Sale’ was to allow
private industry to recover the valuable metals: copper,
nickel ~~d ccbal~ • . The original request for bid offered ~~e
bidder several al~ernatives. The pur~~aser could use the

• … _.
WLA 2108
existing site for purposes of concentrating and extracting
any desired material, or he could remove the residue from
the site for processing or utilization elsewhere. The
materials remaining qfter the purchaser’s processing operations
were over, could be disposed of oy b~e purchaser at the
Weldon Springs dump site whether or not processing was done .
on the present site or elsewhere. The Weldon Springs Quarry
Dump site was a pit located in St. Charles County on Missouri
State Bighway No . 94 apprc:;;imately five :niles SO’.!th~·;es t of
the Weldon Springs plant and approximately 30 miles from the
airport site. The site was accessible by tru~~ from Missouri
State Route 94 and a spur track lead off the eristi:1g east
way of. the Atcmic Energy Co~~ssion•s plant track system providing
railway access to the dump pit.”
Later in 1960, word was received that it was quite
.-unlikely that the private contract would be awarded since ~~e
United States Geological Survey forbade the dumping of the sludges,
processed or not, into the quarries in question because of the
high probability of contaminating the Missouri River shortly
above the im:akes for the St. Louis City and St. Louis County
WLA 2109
water supplies. Due to the many problems, the St. Louis
Area Office was contacted by Oak Ri dge Operations and asked
to hold up awarding any contract on airport sludge.
The material was subsequently obtained, in 1964,
(see APPENDIX B) by Continental Mining & Milling Company of
Chicago, Illinois. Continental bor rowed $2,500,000 from
Commercial Discount of Chicago to buy ane p~ocess the residues ,
using the resieues as security . Continental mvved tt~e mate=ial
from the airpor t to the present site on Latty Avenue. This move
required t en d~~ t–u~~ s for five months and cost Continental
$100 , 000. They were unable to maintain the loan pa~nnents while
~~–.—~. …..- -e- ‘””””” ” ~
they w.ere moving the material, so Commercial foreclosed ti · 1..:~ ~-~- – · .. ·
. • =·: .. ‘::~ ••• • “‘·
·.. ~ ~- “‘::::· ….. ·. ~ …. .. .
.. . ,., ..
-~·· :.. ·· … “” ____ _
The Cornroercial Discount Corporation paid $800,000
for the raffinates at a public auction of the assets of the
·· Continental Mining & Milling Company. lt was their only recourse
to protect the $2,500,000 investment they had in the raffinates.
In this foreclosure procedure, t hey obtained besides the 100,000
tons of waste mat erial, an office building, · three plant buildings
and the prope~t upon which the residues are now stored. ThE~e
• •• I
WLA 2110
residues were again offered for sale at a public auction on
February 3, 1967, and they failed to draw a single bid.
Commercial D. iscount decided to process the residues
themselves by drying and shipping them to Cotter corporation
for mineral extraction (License No. SMC-907 (40-7603)]. The\
consulting firm of Ryckman, Edgerley, Toml~nson and Associat~s
(RETA), were retained to advise them on radiological heal~~
and industrial hygiene problems. In Novembe~, 1968, Co~~ercial •
Discount discontinued operation and the site was shut down.
In August, 1970, Cotter Corporation began d=Yi~g
,.. …… ___ ..&..,.: ___ iT.: _____ \.~- ~,.’t’f’\,.,,_-.~ 14A f’ltl’\.-…e-\1″1 –.:1 –‘–~ ~-.._., …..,_ -1:”—–•·•- a..–~-··– •”””-‘• ._,….,.., ..-w….. \,W WWJJf.;J ~f.””‘ Q,.;)h.C:Y. A~..C.I\. \..V
assist them with personnel monitoring ~~d related =aeiological
health aspects. In-August, 1971, Cotter Corporation had completec
shi?ment of the Ccn;o raffinates to ~~eir processing
site in Colorado. Low concentrations of valuable metals and
other elements rendered the remaining material economically
unfeasible to process in like manner.
Pre~~ntly, the remaining mat~rial stored on the site
includes (see FIGURE 2):
(~ \ ….
–· RETA &
Wl A 21 1 l
I •’ t r’ I \ [ ,, I
. “‘. l !!f· a
-r, ~ MUST BE ,
RU99”. & ~ MISC. DEBRIS :
. f
0 . ·”‘
(1) Colorado Raffinate- 15,000 tons,
containing about 4S tons of uranium.
(2) Leached Barium Sulfate Cake- 8,700
WLA 2112
tons, :ontaining about 7 tons of urani~~.
(3) Miscellaneous Residues – approximately
200 tons, containing approximately 2 tons
of u.raniun.
These resicues are stored in deteriorated steel drums
and sparsely distributed aw~ng pieces of clothing, boots, floor
tile and other debris which render t he small aiUount of uranium
economically unobtainable. The drums are dete~ioratec to such
A more detailed description of the material remaining
can be found in A??ENDIX 3, pages S-11.
Referring to F:i:G”‘uRE .2, Bui!din9 “D” is the only buildillg
whic.~ wil! r;.~e decontaminatior: . !3uilding .. A” is an
office while Buildings •a” and ~c” were used for maintenance and
(- ~ .·
WLA 2113
storage,only. These ~~ree buildings were protected from
contamination by radioactive dust during ~~e drying operations •
.Building-. “O!’ housed the drying operations a.”ld is
slightly contaminated (:0.5 mr/hr}. To deconta~nate this
building it is first necessary to disma”ltle and steam clPA~
the dryer, conveyors, air pollution equipment, and other
miscellaneous ma~~ine~J. This equipment will then be ha~-~¥
from the ·site for subsequent salvage.
After all equipment is removed from the building,
its earthen floor will be stripped to eighteen (18″} inches
below ~riginal grade* The ceiling and walls will then be
scrubbed to remove any dust ?articles. Finally, the earthen
floor will be brought back up to existing grade using clean,
compacted fill material.
~e second step of decontamination requires that
all uncontaminated solid wastes be remcvee tc a licensed
.sanitary landfill.· Items which will be removed include logs,
trees, brush, abandoned appliances and other miscellaneous
WLA 2114
debris,_ which has been dumped on the site by area residents
during periods when the operation had been shut down.
All remaining Colorado raffinate will be loaded
into railroad cars and shipped to Cotterts processing site
for storage. At present, no economical means exist for extracting
additional metals from this material. The procedure
to be used for shipping the Colorado raffinates will be si~lar
to that for the Congo residue, except that the drying operation
will be omitted.
After the Colorado raffinate is removed, the remaining
de?ris, including the leached barium sulfate, will be t~cked
to the Weleon Springs Quarry dump site, as per the original
1960 proposal. After removal of the radioactive materials
from the area, the top soil will be stripped to a depth of 18” ,
.-or until radioactivity levels come below specified limits (Title
10, Section 20.105}. ~his material will be used to provide cover
for the residues in the Quarry.
WLA 2115
To recapitulate, it is proposed that the Weldon
Springs Quarry Dump site be used as ult~~te disposal for
the following materials:
Leached Barium Sulfate 2800 c.y.
.Rubble & Other Debris 1000 c.y.
Deteriorated Steel Drums
& Miscellaneous Ite~s 1000 c.y.
Stripped Top Soil 19200 c.y.
TOTAL QUANTITY (approx.) 24000 c.y.
· A cursory visit to the quarry on May 3, 1972, showed
the area to be satisfactory for this use. The entire
premises is a secured area,,adequately fenced and equipped with
caution sigr.s. Evidence of past dumping was quite visible and
showed a mound of reinforced concrete rubble, steel dr~~s,
miscellaneous construction metals, an abandoned fork lift and
·othe~ equip~ent. The floor of the quarry is easily accessible
from State Highway 94. By carefully placing the radioactive
. residues and covering them with the stripped top soil, the
dumping of this material could, indeed, enha~ce the overall
appearance of the site.
WLA 2116
As noted in the 1960 proposal, there is some concern
with possible contamination of water supplies. It should
be noted, however, that the quarry is placed high above the
flood level of the river and; hence; there is no danger of
flooding the quarry. Also, past experience with the residues
at the Latty Avenue site demonstrated that the material does
not exhibit a tendency to “leach” into the ground water. Since
beginning work with the residues in FebruarJ, 1967, there has
been no evidence of ground wa~er cont&~ination at ~~e storage
n \ ….. __ ~ ,” ;
WLA 2117
_, ,
Because of its inherent. physical properties and/or \
radioactivity level, major health problems are not a~ticipa~ed.
Precautio~s will be taken, however, to insure that no conditions
develop which will endanger the health apd safety of
employees and the general public.
Personnel Monitoring
As stated in the Application for source Material License,
(see APPENDIX C) “each worker will be issued a fiL~ badge.” It
is proposed ~~at for the decont~~nation work, the film badge program
be discontinued. Under Section 20.202 (a) {1), personnel
monitoring is mandatory for persons, over 18 years of age,
-· entering a restricted area that receives, or is likely
to receive, a dose in any calendar quarter in excess of 25 percent
of ~~e al!owable dosage. Previous experienc~ (see TABLE 1)
has demonstrated that employees working at the site have not
been exposed to dosages in excess of the allowable 25 percent.
22 M
22 120
12 90
22 210
22 230 10.5
12 60
20 200
10 50
21 210
4 M
Not Issued
11 120
ll 120
11 130 ll.S
Average dosage – 1.8 mr/~k = 101.4 mr/qtr.
Maximum allowable without personnel monitoring;
25% of 1-1/4 rem = 312.5 mr/qtr.
WLA ~118
136.5 mr
153.4 mr
*Records obtained from Film Badge monitoring program for
period of drying operation (8/70-2/71).
(} ‘ .
WLA 21 l .[._. __ ___lil_ St_a:e_ ~;_ci·_Mix_er ____ _..,. _..~. — H,’,,” 03
~————-~ Saub
—–<"'>f __ “””!””” ________ (
.::::::;.;– o~:::~~:~
Sttil”.\, 10 Stage Kidi·Mixer Scrub
Aqueous Product
. . .
A flowsheet for tne removal of otnar than the thoriu~ and uranium
has noc been developed and this now see~s a reasonabl~ Ching to
do at chis point. I£ ten or fif:een c=u~s of this ~ac~rial were
p~ocessed to dev~lop a flowsheet for the ~ecovery of the tho~iu~,
uranium, copper, nickel, cobalt, seleniu~, and a ~are earth fraction,
it migh~ be possible to raduce L~e ~adioactive contamin~tion
of the final waste raffinates such that they would be no problem
and could be disposed of almo·s·c anywn.ere.
The 250 kilogr~s of thorium-230 contained in these raf!inates
are more interesting than ionium per se; cost esti~ates are already
in existence for irradiation to protactinium-231 and subsequent
irradiation co uraniuc-232. Mound has ~welve thoriurn-230″slugs
on hand that were irradiated in the MIR at Idaho Falls i~ 1960.
It· •is planned to process these capsules in order 😮 develop a flowsheec
for the production of ?rotac~iniu~-231.
Augusc 15,. 1967
– 8
\. ·,


1977-07 – DOE – Preliminary Report on the Results of a Radiological Survey Conducted at the Former Cotter Property

Data Capture
Document Discovery
(Iltis form will be used in recording the document information in the Site Research Database after the completion of the
scanning of the document.)
Reviewers-fill o11t all information. tbat applies to the document then place Ust in front of the document
Siw/Facility of Review: Date of Review:
Site That Document Applies To: Documem Type:
DOESile 0
AWE Site
Document Title/Comment;: _________ _
t?10rJ- ifl-!& ,k. 51Te retprfm
r-r3vlt of= 4olrllkfgd 5’vN>tJ-Irt7
Keyword(s): ——-
HistoricaJ Ia formation
En.vironmental Data
Workplace Monitoring Data (i.e.; contamination
s~s, general area/breathing zone air sampling,
radonlthoron monitoring, area radiation surveys,
fix.ed location dosimeters, missed dose information,
Radiologi~ Ccntrollimits, Radiation Work Pennits)
Process Descriptions (i.e.; general description,
source tenns, encapsulation/containment practices)
Site Dosimetry:
Medi~aVX-ray & External Dosimetry
(i.e.; TLD Film Badges, Pocket Ion Chambers)
Internal Dosimetry {i.e.; urinalysis, feca~
In-Vivo, breath sampling, radon/thoron, nasal
Monitoring PrograiU Data (i.e.; analytical
methods for bioassay, dosimeter performance
characteristic~. detection limits, exchange
.frequencie!i, record keeping practices,
meastnment units)
Internal Information (i.e.; radionuclides
and associated chemical forms, particle size
distributions, respiratory protection practices,
solubility class).
CJaimaut Specific Document
Re<:ords Staff- flU o~~-tb¢ f~U.o~~g.prior to sc:arf~ing ·or wpyi&g () /000 ls-!l. . . . . Project Box Number: :·· Pr~j~~Dol:ument ~umber: ·: . ~ Folder Title:_·_.·_·.....__ ___. ....;-.,._. ......._ _._..,..:~-~.. ....,_--;--...:..;.;._...,...... ___- -.:.·-:·:. ._,·, .,..:.;...•. .....;-.·- '-:'-........... ;...._7------'-_...;_--...o........: . . . . : ,.;. ~· : .. ~ · .... -..... :-, .: ·. ·.· .. .. ·.· ~: • • -:4 '.:· : ~.:·:~~:· · . ...·.· .. . . . . -: ··. ·· . . _, .... :·· . :'. ·;·. · .... " . . ',1: . ',• ... : . OCT 21 1983 ~tr. John E. Baublitz. D1 rector';:.:_ D1v1s;on of Remedial Action Programs Office of Terminal waste Dhp!osal and Remed1 a 1 Act 1 on · ....... Office of Nuclear Energy Oepartment of Energy wasn1ngton, o.c. lOS4S Dear Mr. Baublitz: .. - This is fn response to your letter of October s. 1983 regarding the Department of Energy•s (DOE) research and development project at the fonmer Cotter Corporation site on Latty Avenue 1n Hazelwood. Missouri. ~Regarding the preliminary survey conducted in late September 1983, by your contracto·r. ·Oak .Ri.~s.e tlational Laboratory. we are aware that not all of the contamination is c~1ned to the p11e of contaminated soil. As indicated in the letter frQn w~ T. Crow to E. Dean Jarboe dated August 22, 1979 (enclosed) only the area identified as Parcel I has been released for unrestricted use. The decontam1nat1on of Parcel 11 was never completed because all decontamination efforts were stopped in January 1979 wnen Colonel Griggs. A1rport Director. requested that we delay transfer of the contaminated soil to the airport until quest1ons raised by Congressman Robert A. Young were resolved. After Congressman Young's concerns were addressed and he agreed that the contaminated soil should be moved to the airport site, the St. Louis Airport Authority decided not only d1d they not want the wastes from Latty Avenue but they wanted DOE to reassume title to the atrport site. We were pleased to note that Congress gave DOE authority and funds to take act1on at the Latty Avenue site. because our planned remedial actions have been ~ont1nually oe·t~ Missouri 63130
Norfolk and Western R.R.
ATTN: Mr. R.S. Michels
Regional Manager
Industria1 Rea1 Estate
.Railway Exchange Building
St. Louis~ Missourj 63101
Commonwealth Edison company
ATTN: Mr . J.J. O’Connor
Executive Vice President
P.O. Box 767
Ch icago , Il linoi s 60690
Missouri Di vision of Heal t h
AITN: Mr . Ken Mj11er, Acting Director
Bu~eau of Radiological Health
1407 Southwest Boulevard
P.O. Bux 570
Jefferson City, Missouri 65101
Missouri Department of Natural Resources
ATTN: M~. Car~1yn Ashfuro. Director
1014 Madison Street
J efferso!! City, ~·1issouri 65101
Mr. Ed McGrath
28 Fr€de rick Avenue
Gaithe rsburg, Mary1and
: ..• ~ … -~ .-= ··: ··.·
‘• !
A radiofogica( survey was conducted during the periods June 27 throush
July 1 and July 11 through July 14, 1977, at the former Cotter property,
located at 9200 Latty Avenue in Hazelwood, Missouri. A summary of the
results is presented here. AH information presented in this report is of a
preliminary nature and wiU be updated when further analysis has heen completed.
There a~e four buildings, covering a total of approximately 18,000 ft
on this ll-aere site. The· buildings are presently being prepared for use in a
chemicoJ coating operation. At the time of the survey, there .were four construcfion
workers on the site. Scaled drawings of the property are shown m
Figs. l and 2.
Summary of Survey Ke.sults
Building 1: This structure measures 120 ft x 100 ft, has a 30-ft ceiling, a
dirt floor, and open areas along the wells (including spoces for
~; 33 windows) totaling approximately 2500 ft2.
Beta-gamma close rates were measun:cl at 1 em above the surface with
G-M wrvey meters on the floor, walls, ceiling, and ~supports. Measurements
on the floor and lower walls were mode at points determined by a 20 ft x 20 ft
grid (see Fig. 3), and additional measurements were made at potnts showing
hiehest external gamma radiation levels. . .. O~erheod measurements were mci§TI
. ‘AUG 8 ·· ~ . . . • –· .dJi;::..- • …..tj;.
. : ·;·i·- -~. .. •. – • . ; :.; : .
. . …..~. -·~: ,~y~~
·— ·-……—– “: ~-~~~’ -~’ — _,_ …. —- —

.,. .. f
-2- .·,
at uniformly and closely spaced points. Results ore given in Table:. J and 3
and Fig. 3. Beta-gamma dose rates in the building exceeded 0.20 mrod/hr
at most poinfl and were as high os 2.4 mrod;hr of 1 em above the dirt floor.
External gamma radration levels at l m above the surface were measured
with Nal scintillation meters and with closed-window G-M meters. Readings
were taken at the points of the grid mentioned before (see Table 1}, and
maximum external gamma radiation levels were determined within alternate
squares formed by the same grid (see Fig. 4). Readings were generally in
·the range of J00-500 JJR/hr.
Direct alpha readings wer~ taken on the walls, ceiling, and supports
with alpha scinti11otion. survey meters. Results ‘ore reported in Fig. 3 and
Table 3. Maximum readings within the grid blocks on the lower walls (that
is, Jess than 6 ft above the floor) exceeded 600 dpm/100 cm2 throughout.
The highest reading ·~as JS,OOO dpm/100 em2• Maximum readings generally
were observed on a steel ledge. Direct alpha readin9s WerP. tt.:~ken at
approximately 5 em above thP. dirt flo~r at a few points; these readi;,g:»
exceeded 5,000 dpm/100 cm2 at some points and probably resulted from
radon emanating from the soi I.
·Transferable alpha and beta contamination lttvels were measured on the
ceiling, wa11s, and supports. Results are reported in TabJe 4. Transferable
alpha contamination levels were s~nerally higher than transferable beta levels;
transferable alpha levels averaged JJS dpm/100 cm2 on the lower walls and
55 dpm/100. crn2 on overhead .surl’aces.
,. · . . ::·· .
. . __ ….. ……,…..:—-·-··-··-·–.. —– ~·-·—–· .. – . .. .
‘ I ‘
·:.::· ..
Roden concentrations in air were measured continuously over 24-hr
periods with Wrenn chambers. Results are reported in Tobie 5. Although
the building was open at all times and underwent several air exchanges per
hour, radon concentrations were as high as 57 pCi/Jiter.
Building 2: This structure measures 60 ft x 50 ft and hos a dirt and
gravel floor. At the time of the survey, the building had
uncovered door, wall, and window operungs totaling approximately
500 ft2•
A survey plan identical to that for Buildjng 1 was employed except
that fewer grid blocks were used; each grid block measured approximately
20 ft X 17 ft (see fig. 5). Results for beta~amma cose rates ore presented
in Tables 2 and 3 and Fig: 5. Beta-gamma dose rates were gencrofly lower
than in Building 1 but exceeded 0.20 mrad/hr in some places. It appeared
that high gamma rodl~tion levels outside the building were in pc~t re~po11S•Lie
for the elevated beto-gam’!’O dose ro~e~ and P.xternol ;om:.:~ :-odi.:;io;·, it:vt:i:i
(see Table 2 •”Jnd F:g. 6) inside the structur~. Maxi.rr.um direct aipha readings
within srid block~ on the lower walls (fjg. 5} were generally in the range
1,300-2,600 dpm/100 cm2. Again, highest readings were on a steel ledge.
Traruferabfe alpha and beta contamination levels we~re slightly lower than
those in Building l (see Table 4). Radon concentrations in air in this open
building were as high as 7 pCi/liter.

·-·-··– —··—-·–······ .. ·.
‘ \ ! l i
, –.
“– :’
– 4-
Building 3: This structure measures 42 ft x 28 ft and has a 1.5-20 ft ceiling
and a concrete floor.
The floor and lower walls were divided into 7 ft x 7 ft blocks, and
maximum direct alpha readings and beta-gamma dose rates were detemined
for each .block (see Fig. 7). Direct alpha readings and beta-gamma dose
rates on overhead surfaces are given in Table 3. Transferable alpha and beta
contamination levels ore given in Table 4. E~ternaf gamma radiation levels
at J m above the surface at randomly selected points are given in Fig. 8.
Radiation levels were generally lower than in Buildings J and 2, except for
alpha contamination levels. Radon concentrations in air did not exceed
1 pCi/liter.
Building 4: This small structure (56 ft x 20 ft) was partially destroyed
in a fire and is undergoing extensive construction modifications,
particularly on thg v·,alls and ceiling. The buildhig has a
concrete floor.
Radiation levels were generC!!Iy low except for alpha contaminct!on on
the concrete floor. Direct alphc.! readings on the floor were in the range
50-530 dpm/100 cm2 (see Fig. 9), and transferable alpha contamination levels
were· as high as 60 dpm/100 cm2 (Table 4). fxternaJ gamma radiation levels
. – at randomly selected points are given in Fig. JO. ·
Outdoor Measurements:· The property was divided into .blocks by a .50 ft x 50 ft
grid system (see Fig. 11). At each intersection of grid line.s,· beta-gamma dose

rates at· J an and external gamma radiation lewis at 1 m were determined •
. • ….. · . . . . . : .. ·· …..
~~———-··· , …
-· ‘-!.

– 5-
Results ore given in lobi e 7. J n cddi ti on, within each block maxi mum
beta-gamma dose rates were determined. Readings for those blocks where
. the maximum within the block exceeded the ~axirMJm of the four corners
are given in Fig. 11. It is evident from the resutb shown in Table 7 and
Fig. 11 that beta-gamma dose rates at t em above the surface exceed 0.20
mrad/hr outdoors over o significant portion of the property.
Resu I ts .o f S0 1” I Sa mp I e A ro I yses: Co ncentrah•o ns o f 226Ro , 238U , on d 227A c
i.n soi I sampt es coli ected during a presurvey visit and in one samp I e taken
from a surveyor’s work boots are presented in Table 6. 227
Ac is in the
chain and is a daughter of
Pa which is known to have been present in
large quantities in some of the residues once stored at the former AEC St.
Louis Airport Storage Site. Strictest NRC limits ·ror ~emitters apply to this
ra d1• 0nucl “• de . 1t appears t ho t sJ• gm·!!n” cant quan t•1t •1 es o f 226Ra , 238U , and 227Ac
ore contained in the soil on the proper!)’, porticli!~dy in the dirt floor in
Po U·I1 d·• ng 1. Be cause no spec:•· r·J C e r~r orts were mao·e to cemove 230rh f rom
pitchblende residue~ stored at the airport site, it must a,e assumed that’ this
radionudide may be present in large quantities. A linited number of samples
will be analyzed for
Th. The ~ample whose locotigq is described as “in
and aroond BuHdings 1, 2, 3, and 4” was token from ·C surveyor’s boots and
was soil and mud from the area shown in fig. 2. This sample contained t20
Ra/g and 110 pCi
Ac/g; the concentration .tJi 230
Th hos not yet
been determined. This sample should be representative of the contamination
beins carried into homes by workers ond visitors on the sfte. •
i f
t l
I • ‘;
•__ :
:· • .,!
….. _~
Table 1. Building 1, floor: measurements at grid points of beta-gamma
dose rates and external gamma radiation levels
Grid point Beta-gamma dose r~te External gamma radiation
(Sec Fig. 3) at 1 em level at 1 m
(mrad/hr) {~R/hr)
Al 1.40 320
Bl 2.40 300
Cl 0.35 240
01 1.50 220
El 1.20 190
Fl 1.00 220
Gl 1.30 240
G2 1.00 160
F2 0.60 160
E2 0.40 190
D2 0.30 160
C2 0.30 160
B2 · u.s:> 180
“”” ·1.30 220
A3 1..30 240
B3 0.50 220
C3 0. 75 240 ..
D3 0.75 220
E3 0.70 210
F3 o.so 160
G3 o.so 120
C4 0.65 140
. ···-
Table 1. (ccn~’d.)
Grid point
(See Fig. 3)
…. ~
…. ¥
.\ ‘ I
.Builcilng 1. floor: measurements at grid points of beta-gar.m:a·
dose rates and external gamma radiation levels
Beta-gamma dose rate
at I’ em
External gawma radiation
level at· 1 m

Table 2. Building 2, floor: measurements at grid points of beta-gamma
· dose rates and external_ gamma radiation levels
Grid point Beta-gamma dose rate External. gar.:..”na radiation
(See Fig. 5) ~t !’em level at 1 m
(mrad/hr) (lJR/hr)
Al 0.08 80
Bl 0.08 45
Cl o.os 40
Dl 0.07 70
D2 0.15 80
C2 0.28 80
B2 0.13 55
A2 0.06 40
A3 0.08 55
83 0.10 45
C3 0.15 55
D3 0.15 105
D4 0.10 95
C4 0.08 65
84 0.14 65
A4 0.15 80

.. 1
Table 3. Direct measurements of a and B-y contamination levels
on upper walls and ceiling in Buildings 1, 2, 3, and 4
Number of Direct a measurements e-y dose
measurement5 Average Maximum Average
(dpm/lOOcm2 ) (dpm/100c:m2 ) (mr::~d/hr)
67 900 ssoo 0.24
36 280 1144 0.16
-16 so 360 0.07
10 cc. a~cause some radon an~ progeny from previous 2000-
cond intervals remain in the Wrenn chamber, each reading act1.:::1ly rep:::csents a concentr.l’!’:i.C;-,
ich has been intet:;J.·ated over a period of 2 to 4 hr.
: ~· t .. ·–· — . ·-· ·–· -~-….,.—:—–.. ·-………….. -. ______ …. ..
… –·
I ”
Table 6. Concentration of radionuc1ides in soil
samples taken inside and near buildings
location Depth 226Ra 2380
(pCi/g) (pCi/g)
In and around Buildings
1. 2, 3. and 4 surface 120 N.D. a
Building 2, grid point C3 surface 28 20
Building I. near grid
point 04 6 – 9 in. 240 190
Building 1, near grid
point 04 0 – 6 in. 130 200
Building 2, grid point B2 surface 16 17
Outdoors, near grid
point GlO surface 3 2.1
Outdoors, near grid point
JCS • near railro~d spur surfa.ce 2700 N.D.
Building 1. grid point Gl surface 430 860
Building 1. grid point E4 surface 320 550
On railroad spur. near Sh’
~u .. wer of 8uilding 1 surface 470 530
Building l, grid point C3 surface 190 420
Building 1, grid point Al surface 540 1100
aN.D. : not determined.
• : . , ….
.. ..
.: 1.3
.. l
. I
• ~~
;=; ;
~– m..
,_ \. ··- .
Table 7. Outdoor measurements at grid points of beta-gamma
dose rates and external gamma radiation levels
Grid point Beta-gamma dose rate External gamr.la radiation
(See Fig. ll) at 1 em level at l m
(mrad/hr) (llR/hr)
Al 0.04 20
A2 0.50 125
A3 0.50 220
A4 0.30 220
AS 0.”35 1SS
A6 . 0.20 155
A7 0.18 180
AS 0.18 170
A9 0.25 155
AIO 0.10 80
All 0.10 65
Al2 0.18 110
Al3 . 0.18 140
Al4 1.20 375
A15 0.18 110
Al6 0.13 45
Al7 0.13 45
Al8 0.11 80
Al9 o·.u 80
Bl 0.03
•. 25
82 0.08 55
83 0.20 95
– ··-·- – – ____ … _. .. _.. .. –·”•• .
t : . . ·-· ·- ‘ .
table 7. (coat~d.) Outdoor measurements at grid points of beta-gaE~a
dose rates and external_ gamma radiation levels
” M ~.:.:
!’!” :.:..
:y;~ .
-~·· .
./ “”. \
Table·,. (cont’d.) Outdoor measurements at grid points of beta-gamma
dose rates and external· gamma radiation levels
Grid point Bet~~amma dose’rate -External_. ga.t-nma radiation
(See Fig. 11) at 1 em level at l rn
C8 0.08 30
C9 0.09 40
ClO 0.08 45
Cll 0.04 20
Cl2 o.os 25
Cl3 0.04 20
C14 0.03 20
ClS 0.04 25
Cl6. 0.05 20
Cl1 0.23 85
C18 0.21 125
Cl9 0.80 3 ….. f;)
C20 ·0.25 220
Dl 0.05 45
02 0.30 170
03 0.08 45
04 0.08 45
OS 0.10 40
06 0.1·3 ss
D7 0.06 . 45
D8 . 0.08 45
·’ ,” .
.· .. , ..
.. •. •
….. -·
\ ·.. ·1
. . I
.: ….

= ~

Table 7. (cont rd.) Outdoor measurements at grid points of beta-gcurJna
dose rates and external gamma radiation levels
Grid point Bet~-gamma dose rate External gamma radiation
(See Fig. 11} at l em level a’t 1 m
(mrad/hr) (~R/hr)
09 0.10 45
010 0.08 45
Dll 0.04 25
D12 0.03 20
Dl3 0.03 20
014 0.03 20
DIS o.os 30
Dl6 0.08 45
Dl7 0.08 45
018 0.08 45
Dl9 0.08 65
020 0.15 220
El 0.55 190
E2 0.06 40
E3 0.04 40
E4 0.06 30
ES 0.05 40
E6 0.06 45
E7 o.os 30
E8 o.os .30
E9 0.04 20
.ElO 0.03 25 .
·- …. -···-. -.– ·–· – —–·
.– — ··-··· … –

‘ !

• ‘:””-:.:,.
‘ ,
Table 7. (cont’d.) Outdoor measurements at grid points of b~~a-garr~a
dose rates and external. gamma radiation levels
Grid point
{See Fig. ll)
Beta-gamma dose rate
at l em
.. : . >
External ga~”a radiation
level at· 1 m

… – — ·- ··–~— -..
—‘ /-·.. .
; .) \ …
Table 7. {cont’d.) Outdoor measurements at grid points of beta-ga~~a
dose rates and external gamma radiation levels
il ·-~·~”!
. . ~
:=.! ..
!..:.~. === :
;;;; -‘l .
.- ‘””;
Table 7. (cont’d.) Outdoor measurements at grid points of beta-garr~a
dose rates and external gamma radiation levels
Grid point Bet~-gamma dose rate External gar..rna radi. ~··:
.. … . . ‘ ‘ .
··. ·::.:. ~ ::· ? ·~.:. .~ :.: . ·:·. .. :~~~·:;~.~:-.~;~-?·::. .
Enci~~ur~s -·.. = : ; ·· ‘\/.-:· ~:
, \ . .-:·:·:~._; ~::-::~: ….. ·-.. … .. .. .
. . ·’:-‘.·
.·. .·• ·
.. . ; -··
. ~ … .:. . … . . : :..: .
….. ~
: …. ·· . !,: :.:· .. · . ·~ .. · .
. ..
,, .,:~:~’i ·. ”-;::\}.~ .
. .. . ~ .
. . · ··:.· ..
‘ t • •• • . . ~ …
I ) ‘ •.., • •• •., • • ; ·•
‘. :.,._. ………….- …’!’·” _… ..:. .·.: ;•’. ._: _;,.·;~.·..·;..:;·..:·._,..· :_.···-,.::….,.; ….;…..·. ~.·;, ..· ~.
: .· ·:
Auome·y Work ·P•o··du· ct·· · ·, . .· .. …..· .. ·. .. · ·· ·.-·~ ··::.. ~ :.: ,t ·:’. ·.~
. . . · ~ · -~ … ~ ~-.. ·:·;~:~:-·.-: ·:.·~ ~.:;~:- ~·:.~: · :·:·.~ :
Prepared .In Anticipation of ~~n’: . .. :. .. :~. .~ !r:.~·~>:·, ::. .~ ‘
.. . ….. ! • • … ..- :.
· … · …. ·. ~· ·
…… , . ;- ~ ……. .
n.ew”+ n /.;._-.. ~——–=l·:_· 1>====9
:!l lia~~.;~;r;m~; win~u~ec======== · ….. ·.·
. · …….. .
.. ‘:-:.:._ ~
~. .. . •.
:-.:~·~;; ….. · .. · .. ·
. ·~ .: .. ,_ :·~
~; .
~:.·~ -~· ….
:..~ .–~
“!·. . : . ; .
. ··
..!…-. · -:.·
~.· .. . .
···.: :·, …. ..
‘ .. · … –
-P-o-n-d·s· _ _
– ·· ..
‘ ~·-·-·
·.~ …… . -· . ;”” .
. ….
.!, ‘ .. ., … ·.~~~
… .. .·, – ··… .
.. :
. f
…. · .• …
l .•f . …;.·_ . :.,.. .
?.~i~t-:., .. •, ·.
0 I . ,……:.
.. ·.···
, … ~ •• . • ‘!’:.• •
•• • : :; ·#
. . ~ .. . · … . . •… ..· -… . .
. ·:· ………. .
::..:,·.; .
…: .· . …
~.:…::• .- ••! .. • . ,. …
. . . ···-·· ·-,. .. · ·:.~· · . ~ tT-·.·.”~ .. ttt ¢ .• !4 . .I A.
Litty Avenue
. . .
0.06 o.os
. ……
c 0 06 0 30 0.100 0~0.02 . • . . • .. – 0.03
.· …. .
.. . … • …. -· • • .;.· .
~—-~o.2o 0 03 ·o.o2
0 0.10 • -0.02
· .. ;:-.’. . .
o.o<- -- ·'· \ .. . · ....... . ·- .-.. ·.•·:~ . : ~··: . •. -·. .·: .. .... :~ ~:~-~ ~~ . ..: ·- . ~~ ... -~··· r·...-- .:~· ;~~ ......... - ~:·r~- . ·:. . .·: ..... :, . ... · . ; ..... , ... ~,. 0.01 .,#~'" • .• ---· .• '.*· .• o.os 0.15 0.01 0.02 0.02 o.o1 0.02' 0.02 0.100.02 0.01 0.01 0.04 0.15 o. 04 o. 03 o.os RADIATION MONITORING SURVEY 0.04 0.03 0.07 Values of Gross Activity in MR/hr. at approximately three feet above qrade. April 29, 1974 0.1 0.25 ·"' ;. ~.. . .. .. . .. . :: ·. . . : .· ._.. .. . ..•.. 0.03 .. ~ o. 07 :..-: .. ~·7 .. ;. .·,.. 0~ 0 0.40 0.12


1966-08-04 – AEC – Health Physics Analysis – Continental Mining and Milling Co

of t~is ins pee t ion. !he majo-c di fGcul ty noted was the lad~ o£ pre-
.cauti o~s by t fle licensee to secure the sto r.1gc locati.on of this
mcc..,l· i :: l. Like,:i.s!ssatj’ Htrvc-ys to
!ihOtf that this r.~acc t·.i.6 visit, the licensee
t.:d cor~ec ted ;;b:ce of t:,e itc::~s c::.:-:c !-.<>d achieved parttol col!lpliance
~ nd t he; 1·1ords “Cuution ~ tt.!..::~oactive t-:a~eri. al” were not ,;,ounted as
needed a3d locks wetc not ~ei~g placed on the eates .
n:e only matter of a poor h~alth physics practi ce noted durLng these
th~ transpC:rt vehicles . The licc:-. :::~e “‘~S t:y i ng t o correct this conditi.
on by keeping the tt~;cks loaded to o:-.:y th::e.: quarters of the allo~.table
h~ig ~t and/or. toe pl~cem~ nt of si~~ boa::d5 on the venicl~s. The licensee
has tall~: chis has
11\Jl teria L ch.::t ha,s lod~ed on c:hz ou ~sice of che be.d on ledges and extendin&
truck bed”‘. \,’hen ;:he v~hicl.:. ::.hen n::~k:::s a con,r.:r, this falls off.
!he licensee’s scbcontractors, tn~ ~tansporti~g contractors, have hired
a man full ti~e co ~ravel along ~his route in a pickup truck and using a
broom and shov~l, clean up this fallen ~:;aterial. Since the conce•,tration
and radi~tio~ levels in this materia ~ is so lo~, this can hardly be considered
a =~~~acion hazard.
The licc n~~e currently has a survey p rog~am in operation which is not
e~:ensivc, bvt is adeGuate to show that a radiation and contamination
~rob l c~ ~ocs not exist.
4\-.;;:refo>c, it ._~ ~he: opinion of thi.s inspecto-c that the prog-ram at tl\e
p::escnt time cal\ be ‘– .. 3idercd safe fro:n a radiological hazard st<>ndpoint,
( c .’ .’•'( ,’- 1: ~·:·). 1
591 ·,~_v
1. J.~cc,~:: ee, _ _ _____ _..C:..o.:n_t _i _rtc_n_t :l_l _?l_i n_l •:::::z_&_.’ti_l _l i•-‘S:::….C_o_m…. ;P:…·~n..;y:.._ ____
2 . .. ~.,:'”.:\!:;~ :’ ~’ South La S:.!!c S~~:~c c ·————– ·————————- • Chic;.go, Ii L::.: _.; 60604
3. ~~~~~l~ ~o(: ) ___________~·–~_-e~2 ___________________________________ L • r. • I AL”!llSI: 4 , 1966
• w~~~ ~( L~~ ?~CC -G~—–~——————————————
3. t ~~:;ector _____________o_ a_ v_i_ d_L_.,~s_c_e_r_ _________________________
6 . S ~ c :;;.; :; o f c(.~l;’ll i.:·:.cc __N_ o_n_c_om_.:.p_l_i<_-_nc_e_ __ ____ ____________ _ _ 7. S'-!ct:.er) o.Z t\~:;u!..::.:.: ~on C.J~Cllilo PO\"D ~rs ~il 0 :" l~e~ncc Condit~ ~n A 10 ~ FR 20. J.OS A 1?.3 s 10 CfR 2C , 20 1 e Lie . Cond. 6 3 e4 c 12 cr:-s 2Q. ?-03(-l.-} c . ;>. 5
D 10 C:’Lll. .,J 3{e} (2) D “-‘1
E …..1.\..S(lri:;;P- CondU:ior. 9 2 21
G c
Clr.s s ~. ~ied :t:-:1 ;:c: … ::: t £on
.- !” );I
;,.,. ~~
~ -… (‘I?
\ ,,
‘ r”J …
,r .
. :r.: · .: :…. -: — t :j
~ C…..J., •
• –
\ ‘ ~ .. _ /
• C0~:’! ~:\::, 7.:.:, ~IINil{G & MII..Lf.NC CO.
· .cii1.aco, XLLl:-::ots
L:.:c:::-:s-s •~o . s~~-S62
9. ‘i:,is is ;;:a io: ici..:~ i.ns;>-~cti on of the licc:~seG <1r:.d vis i t s h;tVe heeo con• ,:uc~euse Su perintendent
X:. Joseph J. Do::~avan, C:xecutiv ~ Vice- President
lZ . An unan~ou:1ceci vis it ~o~as ::;:…::~ co the licensee ‘ s faci li.ti es i n Ha7.e l\lOOd ,
Kissouri, on X~y 16, 1966. A v~si: ~as ~~de to the office o f Kr . Jcseph
J. Dor..svan, Chicago, Illir.ois, o1: •. :;;.y 17, 1966. The ! nformat!.on oi i:hese
v isit::: i.s cover.ed in o:1 ii’..;. .. i:::; :-:. . a::::o dated Hay 27, 1966. Details of these
vi.si t s a.re <• i so cov"'-::~d i~ this •~po·:-t:, a.-:~ iterr.s oe noncorr.;> liance t.;i th
s:..sbs cq~.: ont,._ .!lct:ior:s .:r2 .. -~~::..-./• c()>Je-.:cd.
13 . On }:.arch 14′ 2.’>.5.5~, the Region !!1 oftice IJeS noafie.d by H. Fred Belcher’
Han3.get: , St. :..o~..:..s a~ea AE·~ o~-:..ce, ~~.l.ldon Springs, Mis souri, that the ore
t”esidues ot t:c.e St. LouL:. ai-.:po~:: had bcae.n sold t o Co t’\t’i.ne.n~al Hinin~ and
Hilling Com~any, and that n:ovement of this materi al from that site shollld
be~~o with:n a 2 month period. This material movement wa$ begun on or around
~fay 1, 1966 .
14. As of August 4 ,1966,34 , 000 tons of t h e Congo :residueSand 25,000 ton& of
the Colorado residues b~·.-~ been moved from tne s t o::a ge location at 50 t;ro'”-n
Ro ~d, Rooerts:on, Hissouri, to the Continental Mini nB ~nd M.i.ll.ing facility
a:: 9ZOO L~;:oximately half of the m:•tcrial that is to be moved,

~) • I ‘ ~
3000 ::. : .s p~t d;ly. I.e t1as esti.Dlat~d by the licen s~e til;r t tl:e moverucnt
of r’4 t..!ri~ls s!’.o;.~ld i,;2 co-::~plctcd by the c:-td of Septembcn~. Licensee cst
ie~;:e-.. th~t by the end of the t’aOV.!.”:lC:np.:my. A.ll .ha uli n~ is concuc tcc bc::\/al!tl che llours of 7:30 .’. ‘.{ 0:1d 4:00 PM co :.s t o r:ot b~ ~:~volved
sourrou~.d the s tor.:ag ~ ;>:ilce in RobeTtsor., Xi:;11ouri .
l’l. to date, the :.i<:.ensee ~as dcne no ~n::occ ssin : of the matl3rials, bu:: has ~er r.~ated.al f:or this lic€:r.se,/~::-;.:o licc::seii>’s facility is locat:eC: on a
3.5 .;;ere p:,):: of g:-o:.~nd ,.,:,ich tha license.;. p;.:rchased f::::o;a the Busy Bee
l~c:tcr~al Serv.i::a Cor..?lmy and 7.5 acr~s which the licensee leased fro:n the
Xo::-~olx a;::,d H.::>stetn Railway Compgr.y, :;’liS ~:c.::. is located at 920~ ‘2-c.tty
A·,•c:1u:2, H:;ze l\lood. t·:issouri, tir.cr« Latty Av”nue dead ile storage area
a~d :::-:.: ;no~..:ctioa buildir.gs. License Conciiacn 9 S?ecl.fl.es that the
transfer of source r~atc:::-~.:1 to tr.,~ l:.censee’s P.a~ehJood, Hissouri, site
is not authorized until fencin~ ~~c locked gates h~ve been insta:lec in
acco:::dance with the licer;!;.:;:~’s mcrr.o dated Fcbrary S, 1966. At the time
of this insyector’s visit t~ the licensee’s facility on May 16, 1966, it
“”G.S ~oce.c ·~hat t”t\e fe.nca had been erected upon the stock pile storage ao:ea,
b~~ ~~~ticns of th~ fence and c~~tain of the gates had been removed for
eE.::e of entrance to the stock pile a1:ea by the ttansfet: vehicles. At that
time, ~ate”ial was being transferred to the licensee’s Hazelwood facility
G.;.~ ~Jas oeing stock piled and stored at th$t location. therefore, the
_ ~~~see ~ in ~oncompliance with Lice~se Condition 9 in that t~~ transfer
of ~~~eri~l was initiated ana the matctial was stored at the Hazelwood,
___Y.Lssouri, ~ita .prior to co~;>letion of the fencine and installation oC the
l o::ks . License Cor.·7as unattended. \{e in(ono.~cd
::h\s i :~spector t ho’lt that: was no t being oonc at that t i,me. . Therefore, com-
;>lHe COtllpliance \lith License Co’:lc:.tion 9 had no:: been ach.£eved as of
•· .. : ~us :; 4, 1966.
no\: th :;>or~ion of the ~ste;.:;: sect~.-n of the ~nd.l ity. This building is
used as an ofi:ice ·b.Jildi-:-:g and is locatec! outside of the. fenced areas.
Tha licensP.e h:1;; ~ l~rg.:l t::~t<'ll fabri.catio:\ building under construction to t1~e so:J ~':. of the office bui ldi. ng ;;o 'be used as a proc!uc tion facility. 'I'his 'bul.lcing is located •~i.t.hi.n t'he (er.c:e tatcd ~h arrel
s~vn ….. ~ area ::..·.~i.cated a:1 average of 0 , ;: ·;~· /hr at ~8 inches from the bat·rels
with a ~::.:.::1::-.u;n oi 10 mr /hr at 18 inches from the barrels . The maxirr.um radi at
:.on level detected at the surface of any barrel o;.~z.s 90 mr./:-.r , 7herefore,
\. .. :e..~·
– .~:i s ted i;’l the un-res trict:(Od areas arcurid the b.nrel s to·r age area such that
a ~ ~t.6ividual could ~eceive a cose in excess of those limits S?ecified ia
;::,is part. .i.e was noted during the revisit on Augvst 4 , t966, ::hat the
perim<:::cr fence had been extended to i.ncl~tce thi.s ban:el storage ;t:;ea, making it a portion of t~~ restricted area. ~- - 5 - 2(,.. At ti~.! ti~c of the v:..sit to the licensee's f<:~ci 1! ty on l':ay lG, 19o6, :-~o s i.sns of :tny t y;>e “~re posted in the are.a. Since the license Rlatliat:ce 1rith
10 en 20.~03(e}(2}, in that signs wari•·~ ~.!le conventional r”d!.ation
.:;.:; t.I.!3USt 4 , 19ii6 , that c~u~ ic:-. s:.g:-.s shc•.ting the ~onventionc.l l: :-.ot:ed that r.o s i gns shot•i.ng t”:-~e
conve:~::ion;.l. ray~’oo l no-:- t hr. worcs ”C.ou t ion or Dan~er • 1\;ldiation
A-:ea” hacl been ;os:ec S c~libra t~c by calculations for procedur es provided hy Nuclea•
Co~~~lt ~n ts Corpor ation such that the actual re~din’ i n counts per ~~nuce
when ~u lt i; lied by 5 . 56 is e~ual t o d~~ per 100 centimecer square.
n \ /
– 6 ~
!-“el>;:.:::y 4, l\166, rafy 16, 1966 visi:: to the licensee’s f::cility, u: ‘dngs facili.tics .
.12. A~:;·,cu:;h t:,e ra.diation levels as c.:!.:.:.ct~cl i.n the :;urvey by Nuclelacad w~ekly film badges on all t>ersonnel and
::’!’.~s~ ~le average bet;..reen 0 and 20 :nrc::~. Some filrn badges
shot»ed ex~osures as high as 4o’ mrem for a single week. The licen~ee indicated
to this inspector that they :1ad so::~e doubts about the Nuclear Cons~
lt~nt Co::-?or~tion film badg~ service since ~ bas~ci on the r~diatio~
:C.:.ve l:s. ~l:totr.. f::om the surv-js, they did r~ot see :·.o>~ people cou lo:l be gc tting
~!..-. ~. . t th~ t!.r.””:e of the vi.si t on. May 16, 1960 • it was note.d that small clumps
of .-::ceri..;.l nad .fallen fro:n the tr~nsport vehicles to the ro<1dway bett~een the t..:c -.:cilities. Radioactivity up to 1 mrad/nr was detected :tt contact ' ' .. '. - s - .,:::.;:;:, ::1:-::s~ ch .. ~tps. ·rhe situ.:1tion W3S cli.scus:>cd ~>i.th the liccncce. .:Jt that:
tb:c, .w.d chc licensee stGt:Cd t:h.:J\: <1ll cf(o.t ‘ec::o~ \·:as at th~ Uc.a•.see’ .. s facility, .orr&
nge::-,_ .. .:s tt~re mace for ~ s~·:~et .::·.·c.;:. de::: and $\lee pet: to pro~e~q 11i t!l the
cleanup of ::::~ -coacibcds.
35. In ~h~ Ciisc’..lssions ~1ith these inC:ividl.lals, i.: vl!s explained that it was
their :aspo~sibility as the licensee, not the responsibility of the s~b-
-.;)n::r<.cto::.:s (materi.al h.:;.~ leo}, to see t'hat this materia 1 was n.ot scattered througiloct ::1-.e unrestt:icted areas. The lice:· .... .:.e stated that they realized t:O:is, .and t:'ley i.' _·e doing every t:!-.~ng they cct:lG to insure that the ~:~ate:-ial haule~s would cooperac~. ~·:censee ;.~aintains recv-rds of the material t:: .·.sported it\ the form of for ~---· · :::\e. vehi.cles. 'Every third veh;;..;:le ht~uling licensee's facility is wcighed0 loaded al\d again empt<::::>~·
~-;.·-., ….. ~ •• ~ :he weight of n:aterial being h.:;.~led on that load. This eveeyn
\ . .. .. ·’
.. .. ef .:
~ 9 –
l’:l~·/h;: at t:.e f ence . lin-a .::·oc.:nd ti1o·.:t vehicle s rcve<~ l c.:; lhoc t he r adiation lP.vel i n the csb oi t:· . .: truck er.d ;:;rou=td the ou\:side of the ve;,icle ~.:as l ess Cl:on 0 .1 mr/hr . Li:>eltise, a survey of the ~,:r.cin~ secu red when ~o<: a tten:lc :>~.:r t~ co'”i> 1~ with that licens-e condition. Y.r. Knockc stated lh<1 t .-:..'.:.:; h~ .:!:'t'l!~ t! t lt3t t.::..:..;.:; otast w wi;~t: the l;.c~:-.43 co~di t ion ctc;ons and that potn~cd out to ~ir. :{:-:.ockc that they ap?ear cci to ba in noncoo?li<:nce t·ri;;h 😮 C7., 20. 20J{c)(2) i n that the sigt>s s::ot~i.:ig the tJo).·ds “Cnution R~di.o:~ctiv e
}:tt e:.:!.cl” tJ~r e not posted around t h~ pcrir.;~ C:er area. in \Jhich ~his i.1<>te~: ial
•.:….::…:::..::.-~-· • – ·- ..;· in t h.s t t’:-,c ~rca <>.::our.ci .:.he t>att’e l stor.,~c .l”:”C,, hod be~~ .
;:;, •• ..$!, ~. ; l·
4 :-“~ ~~tion ;;.:::ea <>.nd no s i ;;nsj <..s such hac :Jce:1 up :tC that l:i~e; but at the +J..'.J ~).::-;: of t he •\ugust 4, 19.>6 v ~s i.t, <'~;: h:.G ~~;::1. cor~ccLed. Li:..c~.rise, the ftct .:~a t :::1 ~ s uas a ·c astric~~G a '!:..:a, or sr.ould have bc~n' a restt·::cted atea, 1•/1\S r:.)CCtl cueing the ea~:ly visit, o.H: the!: llS of t hic August 4• vis!t , thi s area hod bec :1 e.:c1cs cd -.;.Jit.h a \:<;.r.c~ anc es such, was no11 a r eseri::c:ed a rea. 1;).th 'License. Co\\d:!.tion 8 ar.d 10 CF.~ 20. 201 i:1 ~ h :tt s u ·~vcys l•ere not. 'o~ ing ".; J;, e ;:() nducted a: ~he t.·•IO Locatio::s s.:-tdfa~ivi 'I:.J.t>.s being t:;’lor:dence f r om the Commissi o:l, and Forms AEC-591 llnd 592
42. !·lr. J. J, ~n.:. .-an, Vice-President , was co:.::acced by telephone 3t his
Chica&o of:.: ;c. on Augus t 5, 1966 . The items noted during tl~h inspe c t ion
\1ere r eviewed w:i th hita a t t hat time. Be stated that as of Augus t 5 , l ocks
had bye~ placed on t he ga tes and would be locked ~en not i~ atte nda nc e,
” ~ . ·.s h~


1986-02-13 – DOE – St. Louis Airport Cake Residues – Congo Raffinates – Cotter Concentrate

1602 Cedar Avenue
Canon Cit y, CO 81212
February 13 , 1986
Edward Delaney
Department of Energy
Washington, D. C. 20545
Re : St Louis Airport Cake Residues a/k/a Congo
Raf finates a / k/a Cotter Concentrate
In “History of the Mallinckrod t Airport Cakes Residues” , presented at the
Denver Mater ials Meeting i n Y~y of 1966, Walter J . Haubach , Isotope Separation
Manager , Mound Laboratories, reported that “most of t he pitchblende
processed by Mallinckrodt was obtained as a concentrate from the Belgian
Congo in 1944 and was shipped to St. Louis from the Congo in 55 gallon
metal dru:ns .”
Af ter processing by Mallinckrodt, t he material ~ent i nto storage and became
known as “Airport Cake”.
Regarding Atomic Energy Act of 1954, Section 40.21 of the Code of Federal
Regulations , Title 10 – Atomic Ener gy Chapter 1 , part 40 – Control of Sou r ce
Q. Did the residues (Airport CAkes) that resulted from this
foreign originating concentrate material meet the specif ications
for domestic source material?
In a 1966 AEC Research and Development Report, MLM-1349, Survey of Sources
of Ionium (Tho rium-2 30) , Mound Laboratory, Miamisburg , Ohio, reports that
“These residues are the best known source of Thorium -230”.
In Harbach•s History, it is reported that Oak Ridge Operations contacted
the St. Louis Area office and asked to hold up action concern i ng the Airport
sludge until “long range requiements f or Thorium-230 could be fixed.”
Q. In what manner , or by what action, where t he long range
requirements f ixed?
Q. Was the Thori um-230 content a consideration when the AEC
a l l owed Commercial Dis count, in 1967 , to transfer the
residues to Cotter Corporation for removal to their Canon
City, Colorado mill site?
page – 2-
Q. Was Cotter Corporation advised by the AEC as to the
Thorium-230 content of the uranium contaminated residues
when they took possession and transfered the material
t o Colorado?
Q. Was the Seate of Colorado advised by the AF.C as t o t he
Tho r iu:n- 230 content when Col orado became an agreement:
state on February 1 , 1968?
Your prompt response to these questions will be greatly appreciated .
Respectfully ,
,) :·~- g,,._.;rt2′,,_,,_
Lynn E. Boughton

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