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

i1 f^-
* ^*wt
SEP 2 5 1980
Date: September 25, 1980
To: Robert J. Schreiber. through Richard F. Rankin
From: Burt McCuiiough
Subject: Westlake Landfill
On Wednesday, September 4, 1980 I joined officials from the Nuclear
Regulatory Commission in an on-site inspection of Westlake Landfill.
The purpose of this trip was to give representatives from Radiation
Management Corporation, who has been awarded a bid to do extensive
surveys of the area, the opportunity to become familiar with the site.
It was determined from an aerial survey that there are two areas
within the landfill which are emitting abnormally high levels of
radiation; The Southernmost area is the result of the burial of
contaminated Barium Sulfate Slags from the Mallinkrodt area of
Destrelen Street Uranium processing plant. The Northernmost area of
contamination borders onto neighboring farmland. The reason for
its elevated gamma radiation is-unknown at this time. The report
which will be done by Radiation Management Corporation should answer
this question.
Westlake Landfill is a large facility. About 48,000 pounds of leachate
per day are shipped by tank truck to St. Louis Metropolitan Sewer
District to be treated.
Geological reports indicate that groundwater flows Northeast from the
landfill into the Missouri River alluvium.
Information which has been printed in newspapers on the radiological
aspects of Westlake Landfill has not necessarily been accurate.
CC: Fred Lafser
Ron Kucera
David Bedan
r’Kbbbie Robinson
Joseph P. Teosdale Governor
Fred A. Lafser Director
Division of Environmental Quality
Robert J. Schreiber Jr., P.E. Director
I if>» r


1971-06-29 – Cotter – Letter to AEC – Weldon Spring Radioactive Waste Disposal Proposal

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


1978-06-16 – NRC Memorandum – Removal of Contaminated Soil from Latty Avenue to Weldon Spring

JUN 1 6 1978
Chairman Hendrie
Commissioner Kennedy
Coranissioner Bradford
JSlpwd) Lee V. Gossi*
ixOocket 40-8035
EDO r/f
Lee V. Gossick, Executive Director
Clifford V. Smith. Jr., Director
Office of Nuclear Material Safety and Safeguards
The staff has been 1n contact with the DOE staff at Geraantown,
Maryland,-who has the responsibility for answering your letter to
Mr. O’Leary dated April 24, 1978. In this letter, we reconcended
that the contaminated soil be moved to the Wei don Spring raffinate
pit area in orcier that the property on Latty Avenue can be
decontaminated and released for unrestricted use. The staff’s conversations
with the DOE staff indicate that DOE is contemplating a
neoative response to our suggested use of Heldon Spring and 1s
preparing a memorandum suggesting that the material be consoldated
on site until a permanent low»level waste burial ground is picked,
which could be years from now.
In the discussion of remedial action alternatives, which was enclosed
in your April 24 letter to Mr. O’Leary, the staff rejected on-s1te
storage because the contaminated material would not be removed to an
isolated area, the material would have to be moved at a later date
(this would mean moving the material twice 1n a densely populated area),
and finally the site could not be released for unrestricted use.
Nothing has happened since that letter to change the staff’s position
that movement of the material to the Wei don Spring pit area 1s the
best solution because the site is remote, it is controlled to provide
restricted access, it is owned by the Federal Government, and last but
far from least, it is already contaminated, and the residues from Latty
Avenue would be only a rainiscule increase in the volume of contaminated
soil and rubble presently existing at Weldon Spring.
•-— ‘ ”
ISTRC FORM 318 (9-76) NRCM 0240 T^ 111 a. GOVERNMENT PRINTING OFFICEl 1976 — 628-824
If DOE insists on their Indicated course of action, 1t could significantly
delay the cleanup of the site because of the complex negotiations
required with the former licensee, Cotter Corporation. The Cotter
Corporation has Indicated that they might be willing to pay for the
movement of the material to a nearby site, but they would resist having
to move it twice or move it a long distance. We view our proposed
solution as the raost reasonable of the available alternatives which
is both technically sound and would also release Mr. Jarboe of a
predicament that was not of his making and 1s currently costing Ma
an estimated $60,OOC/year in cash and an Indeterminate amount 1n lost
business because of the delay in building his chemical plant.
I therefore recorwend that Mr. O’Leary be contacted by phone to
reitterate the need to solve this problem as rapidly as possible
and that disposal to a site other than Wei don Spring would only
cause additional delays.
Clifford V. Smith, Jr., Director
Office of Muclear Material
Safety and Safeguards
67 778
67 778
CVSmith,Jr. LVGossick
NEC FORM 318 (9-76) NRCM 0240 “£? Ul 3. GOVERNMENT PRINTINO OFFICE! 1S78 –
If DOE 1nst«ts on their indicated course of action. 1t could significantly
delay the cleanup of the site because of the complex negotiations
required with\he former licensee, Cotter Corporation, The Cotter
Corporation has\1nd1cated that they might be willing to pay for the
movement of the Arterial to a nearby site, but they would resist having
to move 1t twice 6r move 1t a long distance. Since our legal hold on
Cotter Corporation Ms tenuous, the litigation posslblltles could keep
a staff of lawyers ttasy for years and still not get Mr. Jartoe out of
a predicament that wa\not of his making and Is currently costing Mm
an estimated $60,000/year 1n cash and an Indeterminate amount 1n lost
business because of the\elay 1n building his chemical plant.
I therefore recossnend thavtlr. O’Leary be contacted by phone to
reitterate the need to solve\th1s problem as rapidly as possible
and that disposal to a site other than k’eldon Spring would only
cause additional delays. \
Cl\fford V. Smith, Jr., Director
Office of Wuclear Material
SaV>ety and Safeguards
LCRousk < 6//4/7S K3L ItyjKjtfa -u....:.. FC RECunningham 6/ /78 . FC SMeyers 67 778 NMSS CVSmith,Jr. 67 778 EDO LVGossick 67 778 NRC FORM 318 (9-76) NRCM 0240 Ul 8. GOVERNMENT PSilNTINO OF.FICEi 1976-


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

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

On June 23, 1976, telephone contacts were made with Dr. E. Edgerley
and with Mr. Phillip K. Feeney of Ryckman, Edgerley, Tomlinson &
Associates, an environmental engineering firm that provided consultant
services to Cotter Corporation on health physics and site decontamination.
Dr. Edgerley stated that while he had visited the Cotter Corporation
Latty Avenue site when the residues were being dryed and shipped to
Canon City, Colorado, he had no personal knowledge concerning ·the
disposal of the material remaining onsite after these operations were
Mr. Feeney stated that he was aware that the topsoil was stripped from
the Latty Avenue site and trucked to a landfill but he did not know which
one. He indicated that arrangements regarding the disposal operations
were made directly between Cotter Corporation’and B&K Construction
Company. Feeney stated that he visited the site to perform a termination
survey after being informed that the disposal operations were completed.
During the first survey he made he found one small spot above 0.6 mR/hr.
He instructed B&K to remove some dirt from this area which he indicated
would be a truckload or less. Subsequently, he returned to the site and
found less than 0.1 mR/hr. By letter dated May, 1974, the results of
Feeney’s survey were furnished to Cotter Corporation. A copy of this
letter with ~ts attachments appears as Exhibit D in this report.
Visit to B&K Construction Company, St. Ann, .Missouri
On June 24, 1976, Mr. Robert S. Davis, Vice President, B&K Construction
Company, was interviewed.· Davis stated that the amount
of material shown on the invoices submitted to Cotter Corporation was
disposed of by trucking to the West Lake Landfill during the period
July 16 to October 9, 1973 with the exception of 5,000 tons. He indicated
that this 5,000 tons represented topsoil stockpiled in one corner of
the Latty Avenue site. He had removed it and then returned it to the
site after disposal operations were completed. This topsoil along with
other topsoil was used to dress the site. He felt that he should be
paid for handling the stockpiled topsoil and that the 5,000 tons was
included in the amounts on the invoices sent to Cotter Corporation.
Davis stated that while there was no charge for dumping the material
at West Lake, he had arranged to have the individual operating the scales
there to record the weights of each truck on sheets of paper. He indicated
he was required by Cotter Corporation to submit these weight sheets with
the invoices. Davis provided copies of the weight sheets which bear
the heading “B&K Dirt Hauling” and the date. The following information is
– 8 –
n WLLFOIA4312- 001 – 0018547
‘ \
recorded: truck number, gross, tare, and net weights. A spot check
was made of the totals of the net weights shown on the sheets as well
as the totals of the net weights for a billing period with the weights
on the covering invoice. No discrepancies were found. There were a
total of 104 weight sheets associated with these invoices. The total
weight of material trucked to the disposal area shown on the invoices
was 48,544.70 tons. Subtracting the 5,000 tons of topsoil referred to
above, the amount of material trucked to the disposal area was 43,544.70
tons. ‘The invoices also show a total of 10,763.41 tons of material were
shipped by rail to ~anon City.
Although the above invoices and weight sheets did not indicate the
disposal area to which the material was taken, Davis stated that it
was taken to the West Lake Landfill. He offered for review a job card
record relating to the Latty Avenue site and several entries were noted
for the period July 16, 1973 to October 10, 1973 which indicated
residue was taken to West Lake from Cotter, Latty Avenue.
Davis also stated that in addition to using his own trucks, he arranged
for much of the hauling to be done by other trucking firms. He made
available for review from his records, bills from these firms. Weekly
billing statements, with drivers time tickets attached, covering the
period August 3, 1973 to October 12, 1973 were noted from Walker
Trucking Service, Ferguson, Missouri. These billing statements contain
the notation “Latty Avenue to West Lake.u Billings were also reviewed
which had been received from the following: Bruce Barnes Truck Service,
St. Louis; Vic Koepke Excavating and Grading Company, Bridgeton; and
H. Reeder Hauling, Inc., St. Louis. On at least some of these billings,
there are entries showing that material was hauled from “Latty Avenue”
or “Cotter” to West Lake.
It is concluded that the material in question is now buried under
about three feet of clean soil at the West Lake Landfill. While little
significance was attached to the actual location of the disposed
material at the time of the 1974 inspection, the licensee was notified,
by letter dated November 1, 1974, that the disposal did not appear
to be within the intent of the Commission’s 10 CFR 40 regulations
(Exhibit E) concerning alteration of source material to obtain a mixture
no longer subject to licensing.
Visit to Latty Avenue, Hazelwood, Missouri Site and West Lake Landfill,
Bridgeton, Missouri Site
On August 11, 1976, two Inspection and Enforcement Region III inspectors
visited the Latty Avenue site and West Lake Landfill site for the purposes
of performing radiation surveys and collecting environmental samples.
The Region III inspectors were accompanied by Mr. Stephen Nagle to the
Latty Avenue site and Mr. Clarence Stein to the West Lake Landfill site.
Messrs. Nagle and Stein represented the State of Missouri Division of
Environmental Quality, Department of Natural Resources.
– 9 –
WLLFOIA4312- 001 – 0018548
The results of the August 11, 1976 surveys of the Latty Avenue site and
the West Lake Landfill site with a narrative and reference material are
attached to this report as Attachment A.
Results of the analyses of the environmental samples taken on August 11,
1976 from the Latty Avenue site and West Lake Landfill site are attached to
this report as Attachment B.
Measurements performed at the West Lake Landfill and analyses of samples
from the area have been reviewed. The following hazard analysis is based
on the measurements and analyses and on information derived from personnel
of the former licensee.
Direct Radiation – West Lake Landfill
Beta-gamma measurements made at three feet from the surface indicate two
general areas where readings above background were noted. These measurements
indicated 0.06 mrad/hr maximum. The measurements at contact
indicated 0.8 mrad/hr maximum, and about 0.1 mrad/hr average. Thus, for
continuous exposure the maximum gonadal or whole body dose would be:
0.06 mrad/hr X 8.76 x 103 hrs
500 millirems/year. year 500 millirads/year or approximately
However, the area has been closed for dumping by Missouri DNR and is
essentially unoccupied.
Calculated Atmospheric Concentrations of Rn-222 at West Lake Landfill
West Lake Landfill area sample analytical results do not indicate the
presence of significant natural uranium activity. These surface samples,
however, would not be expected to be representative of material which
is reportedly covered by overburden with a thickness of approximately
one meter.
According to information provided by the licensee, the covered material
consists of approximately 7 tons of natural uranium in about 8,700 tons
of barium sulfate and about 39,000 tons of soil. Thus, an approximate
natural uranium weight percentage of the mixture woul~ 7be 0.015 percent.
With a natural uranium specific activity of 6.77 x 10 Ci/g, th~ 10 specific activitl4of the mixture would be approximately 1.0 x 10
Ci/g or 1.0 x 10 uCi/g. Analysis of two surface samples from the Latty
Avenue site (source of the covered material) ind!~ated natural
uranium concentrations of approximately 1.0 x 10 uCi/g, which supports
this estimate of average mixture concentration. !~e Ra-226 analysis
showed an average concentration of about 1.0 x 10 uCi/g for the two
– 10 –
n WLLFOIA4312- 001 – 0018549
Calculations have been performed to estimate radon-222 emanation from
the ground,_1ue to buried material with an average Ra-226 concentration
of 1.0 x 10 uCi/g below a depth of 100 em. These calculations indicate
a total release of approximately 0.1 uCi/sec of radon-222 from the
ground due to the covered tailings mixture. It should be noted that
the assumed depth of burial yields a reduction of about a factor of
three below what emanations would exist, assuming no cover.
Additional calculations were performed using the ‘·’virtual point source”
method for determining average air concentration of radon-222 above the
covered material. The area was estimated to be approximately square,
lith a dimension of forty meters. This calculation yielded an approximate
0 atmose2eric d!spersion coefficient in the center of the area of
f.7 x 10 sec/m •
Applying this coefficient to the release rate of 0.1 uCi/sec_~ields jn
average increase in background air concentration of 1.7 x 10 uCi/m
directly over the covered tailings, which is about one-half of the
10 CFR 20 unrestricted area concentration limits. This Rn-222 contribution
in air, due to the buried materials, would be indistinguishable
from backcround within a few hundred meters from the landfill. Based
on the conservatism of assumptions, this atmospheric concentration of
Rn-222 is considered an upper limit. Calculations are appended to this
report as Attachment c.
Other Pathwa;ts
Pathways other than direct exposure and inhalation of radon-222 and progeny
do not appear to be significant. No likely means of an ingestion
pathway were identified, and inhalation due to fumigative dusting can
be discounted since the material is covered and not subject to b~coming
airborne. An evaluation of the potential for groundwater contamination
could not be made in the absence of information concerning the hydrogeologic
character of the local area. Three shallow (about 20 feet)
wells in the area were all found to be dry at the time the IE:III
inspectors visited the site, precluding collection and analysis of
groundwater samples. As noted above, barium sulfate and u3o8 are known
to be insoluble in water.
Future Development
It is noted that the radium 226 concentration of materials
presumed buried at the West Lake Landfill approximates that found
in tailings materials used for leveling, aggregate and backfill
under or around the foundations of dwellings in certain western
Colorado communities. Some of these Colorado dwellings experience
indoor radon 222 concentrations capable of yielding exposures
approaching those implied in the occupational limits of 10 CFR 20.
Differences in the physical and chemical natures of the West Lake
Landfill and the western Colorado tailings, however, suggest a
lower radon release fraction for materials of the type buried
at the land fill. Recognizing the potential for radon buildup in
– 11 –
n WLLFOIA4312- 001 – 0018550
dwellings and the uncertainties concerning certain parameters needed
to estimate that potential at the West Lake Landfill, a complete
environmental impact assessment is necessary to accurately evaluate
the hazard potential for this pathway.
Comparison with 10 CFR 20 Criteria
Finally, it should be noted that a licensee may bury up to about two
tons of natural uranium per year (in twelve increments) within criteria
contained in 10 CFR 20 concerning depth (4 feet) and spacing (6 foot
spacing between locations). Thus, in four years, eight tons could be
disposed of in forty-eight one-sixth ton batches buried in a grid with
six foot centers: Such a grid would comprise an area significantly
smaller than that found in this case, while containing about the same
quant~ty of disposed uranium.
0 0 0 0 0 0 0
0 0 0 0 0 0 0
0 0 .o 06 ot 0 0 “‘ 0 0 06 ot 0 0 0 36 ft “‘ 11 m
0 0 0 0 0 0 0
0 0 0 0 0 0 0
0 0 0 0 0 0 0
“M·–~~ y 36 ft :’~ 11m …. “:c..;. —-·-.. ~
Seven tons of. uranium could be disposed of by burial in accordance with·
10 CFR 20.304 in an area significantly smaller than that now existing
at the West Lake Landfill. Based on our estimates of maximum potential
exposure conditions by various pathways, it is concluded that the
material now present at the West Lake Landfill does not represent a
radiological hazard by any pathway yet identified. Based on studies of
the use of uranium tailings for backfill and leveling under and around
residence foundations in Colorado, it is estimated that increased indoor
radon and radon progeny concentrations could be experienced in structures
built directly in or on the disposed tailings. An environmental
impact analysis is required for an accurate estimate of the hazard
potential for this pathway.
l •. Attachments A, B, C and D
2. Exhibits A-E
3. References 1-4
– 12 –
WLLFOIA4312- 001 – 0018551
During a survey performed by this office on August 11, 1976, to
determine the effectiveness of Cotter Corporation’s decommissioning
of their Hazelwood, Missouri (Latty Avenue) site, a difference in
the radiation readings supplied by Cotter and those found by this
office was noted.
On May 10, 1974, Cotter reported exposure rates which ranged from
0.01 to 0.4 mR/hr measured at three feet above grade (type of instrument
unknown). (Reference 1) These values were the basis for
·termination of the license by the Directorate of Licensing.
(Reference 2) The Region III August 11, 1976 survey, made at the
same distance, yielded readings ranging from 0.3 to 0.8 mrad/hr
beta-gamma. (Reference 3) Additionally, a survey at one centimeter
revealed t~o areas reading 1.2 and 1.8 mrad/hr beta-gamma. The
instrument used by IE:III inspectors in performing these measurements
was an Eberl~ne E-SOOB with an end-window Model HP-190 Hand Probe
(1.4-2 mg/cm ).
The presently acceptable limit for release of ground areas, as implied
in the “Decontamination Guide” (Reference 4) is 0.4 mrad/hr, total,
or 0.2 mrad/hr, average, with a maximum of 1.0 mrad/hr, all of which are to be measured at 1 em with a probe of not more than 7 mg/cm 2
of total adsorber. Thus, the NRC Region III survey of August 11, 1976 ·
showed radiation levels at the Latty Avenue site exceeding the acceptable
release limits, while the survey performed by Cotter Corporation
showed levels within the guidelines. Both surveys indicate a low, nonhazardous
radiation level. The difference in results might be
artributable to differences in instruments and procedures used. The
August 11, 1976 surveys were the first independent examination by NRC
of radiation levels at the Latty Avenue site.
n WLLFOIA4312- 001 – 0018552
:2: r
~ .w…..
.0.. …
01 w

Sample No.
.. Note: 1)
Analytical Results by HSL
Results (uCi/g)
Sample Description
Wet Sediment From
Cold Water Creek

L-1 through L-4 collected at Latty Avenue Site
W-1, W-2 collected at West Lake Landfill
Natural Uranium
1.2 + 0.1 E-4
7.5 + 0.1 E-5
2.6 + 0.2 E-5
5.3 + 0.4 E-6
5 + 2 E-7
5.3 + 0.4 E-6
L-3 vegetation dried, analyzed dry, reported as wet weight
L-4 dried prior to analysis
A systemic error of + 20% should be assigned to Ra-226 analysis
due to uncertainty of the equilibrium between Rn-222 and Rn-226.
An 80% equilibrium ratio was assumed.
1.4 + 0.03 E-3
5.14 + 0.14 E-4
RI\-222 Emanation Calcula’tions
1. Rn-222 at the Spoils/Cover Interface
Total release • (area) ~ (source flux) ~
• (1600 m ) x DC (A/(DS))
. 0
Kraner. et al, the Natural
Radiation Environment, 1964
D • 1.5 x 10-2 cm2/sec 1 x 10 -1 == 10% “emanation power”
. 3
C • (1.0 nCi/g)(1.6 g/cm )(1 x
0 . 3 3
• 0.16 nCi/cm = 160 pCi/cm
(fraction escaping solid soil gas)
Tanner, The Natural Radiation
Environment, 1964
A • 2.099 x 10-6 sec-1
s – 0.25 0.25 • soil “void fraction”
‘Total release= (1.9 x 107)(1.5’x 10-2)(160)(2.099 x 10-6/(1.5 x 10-2 /0.25))~
• (3.84 X 107)(3.5 X 1~-5 )~
Total release = 2.3 x 105 pCi/sec over 1.6 x 107 cm2
area release= 1.44 x 10-2 pCi/cm2• sec
2. Rn-222 at the Surface of the Cover
c2 • c1 exp (-Z(A/D)~
. -2 . 2 = 1.44 x 10 pCi/cm •
• 1.5 x 10- 2 em 2 /sec
• 2.099 x 10 -6 sec -1
Z • 100 em
Tanner, The Natural Radiation
Environment, 1964
C2 a (1,44 X 10-2) exp (-100 (2,099 X 10-6/1.5 X 10-2 )~)
• (1.44 x 10-2) exp (-1.18)
• (1,44 X 10-2) (0.31)
C2 • 4.4 X 10-3 pCi/cm2• sec
Entire area: (4.4 x 10-3) (1.6 x 107) = 7.0 x 104 pCi/sec
Therefore, the total emanation rate is about 70 nCi/sec, or about
0.1 pCi/sec.
.n ‘
WLLFOIA4312- 001 – 0018554
… 2
3. Atmospheric Dispersion Coefficient
X/Q • 1/rra y a z u
a and a are calculated using the “virtual point source” method
d~scribea in Workbook of Atmospheric Dispersion Estimates, as
a. for a square area with 40m sides, a yo • S/4.3 • 40/4.3 • 9.3m
b. in the area, ay o = aY • 9.3m
c. at 20m (center of area from side), stability class E, and
ground-level release, o z = 1m
d. assume annual avg. windspeed is 2 m/sec
X/Q • 1/(3.14)(1)(9.3)(2) = 1.7 x 10-2. sec/m3
4. Concentration in Air
Concentration= (0.1 uCi/sec)(l.7 x 10-2 sec/m3) • 1.7 x 10-3 uCi/m3
&……. .•
n WLLFOIA4312- 001 – 0018555
. ·. ….
OCTOnER 20, 1976
‘Pursuant to the ongoing investigation of possible uranium/thorium
contamination at the Latty Avenue site, Hes::a :{. J. A. Pagliaro and
G. T. Gibson performed a site inspection on October 20, 1976. The
pu~pose of this inspection was to identify the property owner from
·county tax records, to survey the property bi:~tn-gamma and
alpha survey instrrnncntaticn, and to obtain selected soil and
·vegetation samples for laboratory analyses,
The records rev:te-v1ed at the St. Louis County Buildine, 41 South
Central, St. Louis, Missouri, were the current county property tax
rolls. County personnel. stated the tax records t!Xmnined were
dated as of July 1976. The record indicated the following:
Address: 9200 J..atty Avenue
Size: Discotmt Corporstion
55 East Honroc Street
Chicago, Illinois 60602
3.5 acres
‘ ………….
Telephone communication t-lith IE: III was performed to ascertain
whether thta prpp,!rt)’ had since been transferred. Additional
information \-1&3 received t·lhich indicated Commercial Discour.t
Corporation had tnmsferred m·mership of the prop~rty in Augunt 1976
to the Bayless Company~ 175 Outer Road Uest • Valley Park, Hissouri.
A site investigntion was then performed and samples were obtoincci.
Figure 1 indicates the relative podtion of vadous buildings,
landmarkc, and locntions of collected samples. The area in Fiuure 1
encompassing the abandoned garage, abandoned warehouse building~
and the abandoned and boarded-up burned bu:i.lding wns estimated to be
approximately three (3) acres. The entire area, in~luding t.:hw
warehouse arc::1 anJ plowed field, y,•as estimated t:o be in e>:cess ~
surface” chunks ranged in size from 4 x 4 x l inches to small flakes.
The material was somctvhat fibcrous in texture. The “yellow surface11
material had an apparent beta-gamma flux of ·10 mR/hr at contact.
Approximately 1. 5 pounds of the “yellot.J surfnce11 was collected for
~·laboratory analysis. Several holes were dug to a depth of 15 inches
but no subsurface yellow material was excavated. ·
Selected soybeans were collected from the plotved field, \1as surveyed with beta-gamma and alpha
instruments. The floor of the wnrehousc was composed of dirt and
broken concrete. Several elevated readings above background activity
were recorded. The highest apparent location was in of
the “mrehouse, beside a suppc>rt column. Readings of up to 0. 8 mli/hr
beta-gamma and 30,000 DPH alpha \>Jere observed. A 11 ~arehouse dirt”
sample, consisting of approximately 2 pounds of topsoil was obtained
for ~~boratory analysis.
Preliminary radiological analyses were performed at IE:III using
beta-garmna, alpha, and gam.111a-spec troscopy instrumcnta tion. The
samples Here then fon:arded to ERDA: Health Services Labo~:atory (HSL),
Idaho Falls, Idaho.
The results of the IE:III analyses showed no detectable activity
in either soybean smnplc. The 11 yello\<.' sul·face" sample shm·1ed · 10 tnR/hr beta-gamma and 4,000 Dl'H alpha at contact with a fm.J grams of materinl. Gcnuna scanning \vith an unshielded Nai crystal indicatcct the presence of unmium isotopes but not thorium and thor.ium daught<~rs. Tho "warehouse dirt11 sample showed 0.3 tnR/hr bcta-gnmma and 26,000 DPH alpha at contact \dth a sample of about 250 g. Ganuna scanning tvith Nai indicated both uranium and thorium and their decay chain produds to ba prcwent • ,v ... I WLLFOIA4312- 001 - 0018557 ... ' ·~· - 3- 'I .. The results of alpha spectroscopic analyses of the two soil samples by • HSL are present~d in T~blc !.below. HSL analyses of the two soybean samples showed only small quantities of naturally-occurring K-40. TABLE I Alpha Spectroscopic Radionuclide Concentration (uCi/u) Th-230 3.61 ++ 0.05 E-02 Th-227 I 4.4 + 0.2 E-Olt U-238 6.64 + 0.06 -g,...o4 U-234 6.52 + 0.06 E-04 U-235 3.09 + 0,07 E-05 Ra-226 5.2 - 0.1 E-0'• Warehouse Dirt U-238 0.3 ++ 0.1 U-231• 0.3 + 0.1 U-235. 0.3 - 0.1 E-02 Ye11D\>~ Haterial
_… …
.. ..
. · * .
~ •
WLLFOIA4312- 001 – 0018558
&,I … ‘ ..
.. .
r-r·· ‘S0~\3.£;./lr.i….:_fJ t!J .. ‘i;>, __ ___._,
i • II I • . I ‘I ‘
I I I I f •
·!’ l : l I I ! ., II. .! I ‘
.i I I’ • I i . ! .l !
!! ‘
. l ~
: i
Lct.•Ll4Y>S: .:tr. Keppler:
June 2, 1976
In articles published May 30 and June 1 (copies enclosed) St. Louis
Post-Dispatch reporter }iargaret H. Freivogel presented evidence that
some seven tons of uranium were dumped in 1973 at the \·lest Lake Landfill
in St. Louis County by an Atomic Energy Commission subcontractor
removing radioactive Haste material from a site in Hazeh>lood, Hissouri.
The area tvas closed as an industrial and sanitary landfill by this
Department in 1974 (a new sanitary landfill in an adjacent area protected
from ground{>later contact now operates under DNR permit). The
closed area where the dumping allegedly occurred may be in direct
contact with groundwater. It has no monitoring wells to permit
evaluation of groundwater contamination.
In your letter to me of February 19, 1976 you stated that “a revie\>l by
the then AEC showed there was no significant health or environmental
hazard associated with the burial”. The letter to Cotter Corporation
from John G. Davis you enclosed stated, “It is our understanding from
your contractor that the material was then deposited under about
100 feet of refuse and earth at St. Louis County sanitary landfill
No. 1.” The investigation by the Post-Dispatch iudicates that AEC. did
not know the correct location of the dumping, the local geology, nor
the actual concentration of uranium dumped. The depth cited must
also be incorrect since no landfills in the St. Louis area contain
100 feet of fill. l must therefore question the validity of the ABC
“review” of the burial operation.
I respectfully request that in view of the concerns of this Department
and the people of the St. Louis area, that the Nuclear Regulatory
Commission takes steps to:
1. Provide me with all documents which might assist me in verifying
the Post-Dispatch report, and in establishing the exact amount
and chemical form of radioactive materials allegedly dumpeJ at
West Lake.
Exhibit A
1 of 4
WLLFOIA4312- 001 – 0018560
• \
.Mr. Keppler
Page 2
June 2, 1976
2. Require the Energy Research and Development Administration,
as successor to AEC’s source material operations, to
a) Include the West Lake Landfill in the areas it has selected
for intensive aerial and ground level radiation monitoring.
b) Locate the uranium precisely within the landfill, both as
to position and depth.
e) Install appropriate groundwater monitoring wells and implement
a monitoring program to determine the extent, if any, of
groundwater contamination.
Recommend actions to be taken to protect landfill workers
and the public from any potential hazards associated with
this material.
Advise me on who would be liable in the event that cleanup
costs are involved.
Ascertain whether federal laws or regulations were violated
by either the Atomic Energy Commission.or its subcontractor
in the disposal of source material at an unlicensed site.
In a related matter, I was disappointed to learn that you do not maintain
records of radioactive waste burials carr{ed out by licensees under
authority of Section 20.304 of Title 10 CFR. I hereby respectfully
request that your office obtain such records from all Hissouri licensees
who have made such burials and make these records available to me.
/~-K.;;~Ce:;..-n~e,…th…….,M””l. .K~,-< arch fh. ~._..---Director K.MK:JE:jhb ee: Robert J. Koke. EPA Region VII Enclosure Division of Environmental Quality Exhibit A 2 of 4 J. .... ~- •• rWLLFOIA4312- 001 - 0018561 :2: r r 11 0 ); ~ .w.... N I 0 0 0 .0.. .. OJ 01 0) N - 1 ~ ~./- _J w~ ~ 0 lLJJ ~ ~ ~dJ£~TC~~ ""._. ~ .. .....,. 1 ,_......,...... , .. ......_~ ...... • .,..,,..\k ...... !-"""" t ~;;.;&x. ( :, .... .~..·,. ,... ......... !i•»• (:.,< ,.,..... e.,., ..... ~. ·--"-·~ ,.,_ • T. u ••• o, .. ;...; ''" -,.. -....... ~:::.7';.._ t ...._.. _..._ t ...,. .~ ... -:. '. \ ......... -... ,h .. --. '!.,:, ·t:.-; t''~ --.~- .1 /' .. .. - .- • f • : . .. t\ Y. ~lAY :~o. I tho.! in
s clc:.rly
l t\ucle.
aid this
!c px~d
· Ato::lic
tra~~ or
In ac!ditlon to being v:ron;:: about the
vo!!.!::::! or th: ‘”:::!::~, f~c!~:::t recc:;o:ltcd at ••st. Loul!l County LondCUl
No. 1 0:1 Old Crldgc no:td.” No such
p!:l~c cxls:s.
Tl:c U t: K vice prcs!!!cnt, D:l\’ls,
cc::!irr.’:c:! lh::.t til:! m:l:~tia! !’;~c! r:o::~ 😮
th~ West L:::.b~ L:::.::d!ill on St. Cl’::::.:-l:s
Roc!: r.oad. St. Louis Cocr.ty ta!l~ml
r:o. 1 is on D::r:;ctt <:!!'!~ t.die noo.C:s, rr.o:~ tt:n !.::::- r:!~!!5 :'..'·~·~:'. Th~ \'lest L.::::~ L:::-:::::~1 \i::!!: e!~:::d tcr:-:~'lr~ri!y in 1'7·! fer irz:prc-.·.:::::::::s bcc~u:c st::tc c::ic!=:!s fC'..:..--:1 t!:::: c~r:~!:: pc!!~::1r.ts ,,·ere lc::!:~::~ fro::-: it in:o the s:.:rrm:::d!::z r.c:::! p:::!:1 ::c!!. t!o tcs~ ror r::~:e::.cth~;!j· \"~·:::: r.::::!.:J !:~:::~=~ r!!ic:~!;; were unaware tl'::lt an}' radio::u:tive m::terials wera in tl:.:! !::::~nil. Bcror~ tlae imprcv~u:c:::.s '\\·~r~ ~~!. II would h:sve ta:er. "irresp::::tlh!e .. to put an)' h:u2rdous \;·.u:! at Wes: Ldke, s:tld J os.:ph Eigner, who tt.:r.s the ~~iSSOt::'i h::.:i::ri!o:;,.; ~·~z!e r:o:;:-::.rn. The pr::!i!e:::l ::< \'.'es: La}:e t::.lj' b·;e been comy~u:.~~~ b:: cs:::~ t~: r~~i::;~ ... ti\·e m:ltcri::!l as a ::-..!: S~!!.
Tt:! t::iu::-: s~!~.1:~ a:.! c:!’:!: -;.:s:c
~:-:-C:.:::s c::;:::~!~i· ~r~:-! s:.::z:! z: I…l~·
b~::. Fie~:!. La:e:. s:;=e c! t:”:c: ,;;e:-i
c~-.-e:! to 3 st:~ a: ~:;;J :.a::r R:.:~ ..
Ha:~:-:.·~. in p;-e;.:::-:;.:;.-:: ::.r r~::x:~
S…””e Ct~:::.:’.:G. F:;~ f
~r i~s
ho.t is
sarr:p!cs c! tl:c tmc::b::!:; t:::::::;; sz:;t to
the lanc:m. hut he ~’.:l:r.awl:::c;;:::d that
tt:cy, teo, eol!ld h:wo t:::::t i:l::cc1.::::::::!.
Fe:!~=-::.! ~uthor!!i~s m:11c no f~C:;:t~r..d …
ent r::c:::surcmc~ts cf the strength of
tr.:lt~r!::l ~nd nor~:!!y net in a case
!il:e tl~is, a s~::!:c!:~:n for the t~uclc:tr
Re:.;t:btory Cor::r::is$::m said. Rc!:,·l::3 0:1
Cotter’s rccorrl.;, a federal inspector
ccncludcd that the eoncen: ratio;~ of
uran:um in the matcri:.t! bdn:; C!.::::lpcd
·was .o~:n per cc!1!–::el! t:::ow the .05
per cent limit set in the rcgu!aticns.
the l!aze!~-:ocd site for rac!!ation ar.d
found it c!c:::’l.
AEC im:cs:i;:ato:s did fin~ !ac!t w:th
one :xs;:;~ct of the was:c disr:o~:.!!. The
agency rcp:ir:::.!:-:~::-d Co:ter Co:p. in a
letter Co: di!c:wly watched by lw; co::•;;.:r.y, llle C~C;Ot,.Ci’r\,”i:; \’:,’A!:ii: storoCjO crccs. t:.cp inoicctes where ‘~
cngln1\.crini~ 111r~~~;-~~ :1 \1vc ‘,~.E~~·.~~-~c,·t.o! the barium sul!cf~ wcs cricir:;il·,· stored, tha ~ite en 92w lc:::/ .J .of
4 ~ th{‘ t 1rcf’t’ ac u'”l ‘ .. “‘””‘ \.. …. …. \\..’li ~… .iiJ ~ .. ‘·t..
,..,,,·,.,;.1 n r .. f.: m,;.,-.. .J 1•: t:n· l<:n:dfill. Rood. ond where 1t v:os moved. the West lcke lcncfill ot St.:...;.~~-:::-_ · t :2: r r "'Tl 0 ~ .w..... N 0 0 0 0... ... OJ 01 ~-··-, ,. ' " .. 1{jj ·lo A o _((l:E}~ J·1D~~J,l~\a E1L~~r~®ll-ofr~IT~: CCfu~~n~§ -tfllillsrl1F~ra1t; E:.· =':!.~:!G.\nET w. fREl\'OGEL • I l.egblature w enact a radiation protection ..~.~t tno~ ur ·.,a,re .md ,.. ..1 : tn i~7; t•> !h”” : … :
Cf :.!le P::s:-O:Sjlatcb Staff f.. ·1·7 ‘-
So :.~nt: ::l!t..~J!!dy rr.1mitvrs radicactive mal~·
rJal:> Ill ~.!., ;.,;t::l :u::l ;!;;: ~:a :c is U:Jjiri!parcd to
h~’!’:C:!e :~cc:c!c::t.~! r~!cases of radJatinn, two
sta:e :.!~:=:a!$ !J::il!lar ‘»’1:h t!le :;itu.~uon ~;ay.
‘T::i: c!:.::;:;!::z :.! SC’.’I7!r:d tMusar.d tens of low.
1!:’~·~ 1 r “‘:!:::;.:.:<~~·r: wa~tr: at tbe \':est Lake ta::~!;ll ::~ s:. l.;;u;:;;. dt<.clcS<:d S::nday in tiH Pr;s:-!):£paah - l.i only one or :if:\'eral m.:.:le:.r-:~!..o: .. d pr1.l;,!·~:n->, sau.l Kenneth M.
Y…I:C!’: ;::-;:! :.!.l:.’IO !\…d1f!.
};.;;.:.~ .; ..:;:.,.:::vr -.: .:r.1;ironmer::al GU:!Iity for
1!:1: :>::m· :’)e;::trt:r.em uf Natural Rt·sources;
!’to;!;:; ::> :::e c!c;:;.:a:men:·s ~irectcr of planning
::.:::! ;;ell.::: de·;e:<:p::ler.r~ T::~re ;s ::o .:~·1der.c:e t!':at the West take C::.::::;:;:~g ~z..:,ec J !-.!':.:::h hlza:d, bur it ap?are: a:\· ::c::-.~:.:s.::d !ec!e:ll aut!:.orities wllc were s:.:;;)oscd ~o te #:~e;::r=o~ tr;.t~k of t!u! materi:ll. F l;~e ::,..; .. ::::;:. re<. d~·:~e.
·Tm .;.:..:: uf :te A:om:c Energy Co::::nis$JtiO·s
n::..::>t c.:::;-:<:::o .::::!:cs." s.Jid O:!v:d P. :\ta::-cou. e:.:ttc:::·.:<: ·;:c" :-:,·~:c!t:r.! of Cott!.'r Corp . whicn ·h.,.! ;: -r•::-;t-c :~c ·x;;,re rr. a ~•·::t;,u::;ed.
.. Ninety-nine per cent of the time they
(f..,Jeral authorities) don’t know wb:u·s gomg on
tven ‘o.l!ht•n th~y havr: someone !\landing there
… As a citizen and as a member of !hls
.ndu:.lry. I’d like tu see them do .J beucr F·:S:•
Maitvll sa1d.
f\vd1!f Jl:.d Karch said they were dl!lturhc:d by
the W .:~t luke incident because It was, In their
opulion, inchcati>e o( serioUS gaps lhal e«iSI in
&he munitorina uf low-lt:vcl waste.
rh~ federal Nuclear ltcuut:uury t:umrrilsslon,
·,\llich replaced ll;e rww cuf:.tncl Atomic E;~ergy
1 Commt:>sioa is too s~orthan~c-d 10 tn-.:cst:~a:e
:c•lrr.prchcnsi\·ely, tbe oHidal.s said. State offtcials
ha\·e no authority to ftll in for the federal
agcmcy, they said.
Thcj’listcd sever~! ;>ro!.:!cms, ir.cluding:
(1) ln:to•.vcr plants situated near
enough to J’.lJsscuri w cause injury tn the sta~e
a::1 fr<1m Union Ell'ctr!c Comp:my·~ Callaway ·Cou:o:y plam ::ow u:-:der •:onstr~wtton. 0} lnadequ:t!c al!ent10o w tilt' transpnrtal!on of r;,dinartive mawri:tl~ throur!h the sratc. TriSt. ll.: ~totor Co .• the largest mmsporter of nucle:u m ba~::d in
Joplm. >tn HQ’Nevcr, mnst •>f Its c::rgo dP~S not
~J<;S lhn>o)!~ ‘.1!sso:Jri. a study by the Dt•p:lrt·
nwn; ‘•I ~; .;\.nl R~sr,urces (oun:J.
!(::rch ‘”ttl :\odrff [ailt’d t(l cunvi!!r~ th::o
dorms th~: !;txt :;ession. II would have t:rr.pu;~.- :-rtt!Jitd at St. Ch .• r:..-:. Ruck R~,;.:;c J:;-! ;,J
ered :;rate ufhcials to m•mitur morl! t>UI!flin:lv Ru:~c!
\\’.ISh.• dl~pusal and lranspor~auon. The ;,;!Jt~ ln. 1· .• 1 . 8″·'” ·•t1·, .. r , ···tt’··’ • . . ••..
-u (f ICi.t ~ls pt. an til orge cnactm~.:nr of r”. . e lll’gt!>’. l!· l•~m ‘.•. f, ‘tt..· ·• ‘ “··” ‘h” ‘ J’· ·r .• ,.\ .u• .:,t .. ,..~~ ”’~. ····.•· • . . …. u ._,,i. • ..,. hu s:u lt..’\:t utJ.O :1\.t\’V
t:an ~g;un next :.t-:.smn. . Rl.’l’.’lll;l ur. iht· ;::.;.lrrn: :::~·m~~·, .11\ ·, “1 he f.-dt•ral a~ent·l~li just arcn’l mannc·~ •., · · ·’·
~~o~ttt·!~ tn~pt· …. :or .:cr.~l •. h.!t·.! t:t~t. the ·•..s:Ht:
&.· …. ;; ~;L::\·~ ~’ ah ~utl t.1”· tb u..!:l·-·~:•
do a tliorucgh and t·ompr … hcnsiw Jnb, .. ~oc.ilU
saul. ”Tht-y’re forced to !>rl priuri\it’S un \\bl .
they lll”~Pt·t:l. Tlwy ~tan With Mry :!0 y•:ar~.”
:\ fctlt-ral .:tomic salety official saia t:e
thmtght th£’ mcnitorlng program was corr.pret:
en~in· enough. · ·
Con:-~qut·1;tl~, Ill.: u;.,;>.:n· r·:- i’c;:••rl 11..
,t:rrur ttfl tl!l’ :-!r.·r.,.:tl:. \ ~·!· .. !’::t- .1:0:..! lu(“‘!” :to
W .. i~tf·. O,! .. p!!e ih’l..~ l:!C.~:·· .. :e\!cr..l! ..lO.! :
u!fH::at~ :;..::.! lt11: :no.k~l;l. r;.:.,J no !:e
~:..z:ml·::•: ch:d .\1!::-~ .J
wnrrtt’d abcut ih·: ‘.0…1:>1~ ~:.::: .. : ,;.;:~: <.!< 51:':1 . F~r:n.o: ne~!~ t"•th.t:rtbtJ. ~.rd. t~~ $Hte.:- t;:~ll;:;t:e!:.:;l
!!H.· h!·. .• .. ~l!·\·er \\:~ … ~.: m.:tt:r:::! tJ …t feJ
ct>;·1s.t: :m~a ::1 Shdf;dd, :n .
All.·rt l-a!t! :h<.· m:t!t!'r: .. !l. 'J:tgtn;.~_r,ng f r€''":lrch pr:;,..,.
v.. J;o; \t”‘r\ ”~;\ 1:1 ~·\:t!!a:!~!: ·:::·’.: ~:::C .. t’ :;’J “”;.
~tl”,:t·:·~-:d !’ly f·/~.!t•:’ :~ !’* .. “~.!…:!~:: 1;.;,
.. ,,.s d1~l!lfbing th:H WI! might ‘h:w~: got
incnrn·ct tnformation (about the ·west Llk~
dis;>osa!).” ~aid James Allen, chief -of the fuel ·
bclltt\’ and material s:tfE-ty branch at th-e
:\ud(•;ir Rt•gu!awry Commission’s rt>gwn~l uffa
·\· 111 f;!en Ell•:n, I!L “Rut whcr. thl’fl··~ :1~
!\t.”.dth ~ta;urJ tn•:oh·t•tl m a situatto:l, stnct bt:! K .• rrh ~;!!<:: ~·: w,:, .!.-· .. :: •. ..: rt .• : ::i:::·: mnnnunng or it W!Hold be takmg Pl'Ople ;r.~ay F:t:'TI· 1::!! nu: !Jn:l ;b ~ ·~.:~::::; :>~:l …. :oJ t~
from mun· 1m;wnan1 ht•a!th lS!>t:e~.” bur: a I w·t~ •nr:t·:! :!’~ ” .:< -. ::;. ,::1,..1 .:I •. • Alkn ..,ald he was nnl <'tmcerned ab()Ut th:: h·Jt"r.!: dho:.t:~ r~l:t"d ~"' ~;..,v::-.: .. :: !·" agcnry bcmg du;wd. Th<' We;;t Lake t·pisode ~a;. i::,!••.tu t1f mO.:··tl:·~d' r.; ·:-\·:·· . .:. ··:··~- ·t "' ·l an l""l:tlt·Ubmlll••d ~::!~r mvu:ees tok (vile: !-‘.;:~, :. i’• , :,·!’•·: ·,~: .. : ~ · :-: :· ··~·. =.• .:: < C<•rp •!• 1.• :!'~ t!:.H tf !;ad m•·\'t"\1 r.•:.u!y !0. J~ ·.\·J~ "':•": ···~~·r~h ·.,r :n· .... ,. Exhibit A 4 of 4 I • UNIT£0 STATES NUCLEAR REGULATOHY COMMISSI"' . .J REGION Ill '7U ROOSI:Vt:L T AOI\0 OLEN ELL VN, ILLINOIS tO I 37 JUN 1 7 1976 Mr~ Kenneth M. Karch Director, Division of Environmental Quality Missouri Department of Natural Resources License No. SUB-1022 P. 0. Box 1368 Jefferson City, Missouri Dear Mr. Karch: 65101 This is in response to your letter dated June 2, 1976, requesting additional in£ormation and follow-up action relative to the burial of some seven tons of natural uranium in a St. Louis County land£111 in 1973. The information published in the St. Louis Post-Dispatch on May 30 and June 1, 1976, which was enclosed with your letter of June 2, 1976, is new to this Office and, as you pointed out, conflicts with the information obtained by our inspectors in 1974. Based on this apparent discrepancy, the NRC plans to initiate a full investigation into this matter during the week beginning June 20, 1976. The findings from this investigation, which w211 be made available to you, will determine the need for further NRC action. At the conclusion of the investigation, all documents relative to this burial will be provided to your Office .. With respect to your June 2, 1976 letter, I would like to clarify one apparent misconception at this time. The Cotter Corporation, which was responsible for this burial, was an AEC licensee --- not an AEC subcontractor. Consequently, the ~nergy Research and Development Administration has no responsibility with regard to this material. As a former licensee, the NRC will look to Cotter Corporation to correct any safety or environmental related problems identified through our investigation. Regarding your other request that this office obtain from materials licensees in the State of ~tlssouri records of low level radioactive waste burials under 10 CFR 20.304, I must reiterate that there is no NRC regulation that requires reporting waste burials under 20.304. Therefore, there is no Exhibit B 1 of 2 r 1 WLLFOIA4312- 001 - 0018564 . . . •. Mr. Kenneth M. Karch JUN 1 7 1976 basis for such a requeot to the licensees. If you believe that the NRC's current regulations concerning auch burials are inadequate, you may petition tho NRC for consideration of a chtinge of the regulations. l'hia rulcmnl~ing petition should be submitted under the provisions of 10 CFR 2.802. a copy of which is enclosed • U you have any questions concerning the above • please let me know. Enc.looure: 10 CFR 2,.802 cc w/o encl, w/ltr dtd 6/2/76! R. J. CokeEPA l'..e.g:t.on VII Sincerely yours, JQmeB G. Keppler Regional Director , .. M., Y. l<"reivogel, St. Louis Post-Dispatch D. P. Marcott, Cotter Corporation bee w/o e.ncl, w/ltr dtd 6/2/76: :J. G. Davis, Deputy Director ·D. Thompson, IE:HQ ·L. Rouse, NMSS S. Schwartz, SLR ·J. Fouchard, PA Central Files IE Mail and File Unit PDR NSIC .. . ' . ·: Exhibit B 2 of 2 i JJ,... WLLFOIA4312- 001 - 0018565 •. ---·---.. -.::~ -:-...:: l•tuho••' ·• ·• .• ,NVOJCt ... HArrison 7-5666 r L .. . . ' .. ____ , ___ ----.--1 Cotter Corporation · ··. =: ~ .. • · :/ • •. -:··· ·.: >·
P.O. Box 751 : · – …. · · · … )
Cannon City, Color:ado ‘81212 .’ ~·
‘;;:-·:~:;~~~ ·..,.,··; ! .. ~~ … :…, __
JOBSITE: Latty Avenue, St Louis County
Material trucked to disposal site
Material shipped by railroad
• nuns
4981.85 tons @$
2341.75 tons @$
Exhibit C
1 of 11
N~ 10B5~
········.- Y”f’OI’~ .# •• 1–:,. …….
• I I •’ “‘•)’Ji .. \
. . . . • \; \”1. ..#·.~~.1’~’-“”~
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WLLFOIA4312- 001 – 0018566
…. ,. … .,., . INVOICE S-.~’!.i>-

HArrison 7·5566 …. t (f ·-·
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• fACton noo•s
o ,AilKING lOT$
JOBSITE: Latty Avenue, St. Louis County
Material trucked to disposal site Aug. 1st thru Aug. 9th -8373.75 tons
Material shipped by railroad Aug. 1st. thru Aug. 9th- 846.70 t.nn~
8373.75 tons @$.02 .(scale charge)
r ___ ,_.—·-·—–~•··-·–·–··-·—— •• -~
~– . -n- .Jif”
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Exhibit C
2 of 11
WLLFOIA4312- 001 – 0018567

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JV}G 21 ·l· .c.. :I :~,:1t
.4000 7·5666 ( t •••• (· t
c • • t c ..
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! f: . .::;!:ff.Y.f..: i~J ~~ ~H B & K”
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f,·~c:.;:;p ::: –~-…:…——:.,/’:;
fjs!r. :.:e~~ V_ , I • OliVfWA’U Cotter Corporation
P.O. Box 7.51
Canon City, Cplorado
j jll.o> “””‘ 1.::;.:.–t”·~=- ~- -~
1 ~t ‘ •• “.-. ·r~c• ~ I .~~p:o>:~d . ·- . . . t1TJ
JOBSITE: Latty Avenue – St. Louis County
August 10 through August 16:
6,304.10 tons hauled to disposal area by truck @S
lJ86. 95 tons shipped by rail @ S
6,304.10 tons ® S scale charge
• nuns


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.[]
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


2014-05-01 – EPA – USACE – West Lake Landfill – Haul Road Information

To: Tapia, Cecilia[]
Field, Jeff[]; Kiefer, Robyn V NWK[]
Cotner, Sharon R MVS
Sent: Thur 5/1/2014 2:17:49 PM
Subject: RE: Haul Roads Information (UNCLASSIFIED)
Classification: UNCLASSIFIED
Caveats: NONE
Dear Cecilia:
I’m going to assume that you are looking for information regarding USAGE sampling of haul roads
between Latty & Westlake (since that seems to be the topic of the day.)
USAGE has sampled and remediated haul roads between SLAPS and HISS since the completion of the
2005 ROD. These roads are Pershall Road, Latty Ave, Hazelwood Ave, a small stretch of Lindbergh,
Frost, Banshee and McDonnell Blvd.
USAGE never sampled the roads from Latty to Westlake Landfill.
The sampling mentioned in the 2005 was completed by DOE prior to USAGE assignment to FUSRAP in
1997. It was only mentioned in the ROD in order to give a full picture of the sampling completed to date in
the area. (In hindsight perhaps it should not have been mentioned.)
The sampling completed by DOE was briefly mentioned in a report completed by DOE. We are trying to
find some sort of document with the actual sample results but are having no success. (At this point I am
not sure we even have the data since the area would be outside the scope of FUSRAP as Westlake was
not a FUSRAP project at the time of the transfer of the program from DOE.)
If we find anything more, we will let you and the State know.
(Also- as a side thought, someone here recalls MDNR sampling these roads in the 2003-2004 timeframe.
You may wish to touch base with them.)
I hope this helps.
Sharon Cotner
—–Original Message—–
From: Tapia, Cecilia []
Sent: Wednesday, April 30, 2014 4:16PM
To: Cotner, Sharon R MVS
Cc: Field, Jeff
Subject: [EXTERNAL] Haul Roads Information
Is there any other haul road information other than the work USAGE completed that resulted in the 2005
WLLFOIA4312- 001 – 0058973
Cecilias Microsoft Outlook Signature large font
Classification: UNCLASSIFIED
Caveats: NONE
WLLFOIA4312- 001 – 0058974


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


2016-07-20 – West Lake Landfill – Evaluation of the Selected Remedy for Operable Unit-1 at the West Lake Landfill

DATED: 20 July 2016
Robert Alvarez
Senior Scholar
Institute for Policy Studies
Lucas W. Hixson
Director, Field Operations
Environmental Services
1 | P a g e 07/20/2016
In 1973, uranium ore processing residues from the production of nuclear weapons, mixed with contaminated soil from the Latty Avenue Site in Hazelwood, Missouri were transported and illegally dumped in the West Lake Landfill in Bridgeton, Missouri. Currently there are known concentrations of radiologically impacted material (RIM) in areas of the landfill designated by the US Environmental Protection Agency (EPA) as Operable Unit 1 Area 1 and Area 2. The full extent of the contamination relative to the potential impact of an adjacent underground fire* has not yet been determined. However, EPA experts indicate that sufficient data exists to support removal of these materials.
In 2008, the Environmental Protection Agency (EPA) proposed a Record of Decision (ROD) related to the Operable Unit-1 (OU-1) at the West Lake Landfill (EPA 2008)3. The EPA remedy proposes “in-place” disposal with the installation of a cap/cover over portions of the landfill and long-term monitoring of groundwater at the site.
Internal communications from EPA’s expert reviewers reveal that the proposed remedy is unlikely to protect thousands of urban residents from concentrated radioactive wastes in the floodplain of the Missouri River.
EPA internal analyses find that:
1. The EPA cannot ensure the protectiveness of the cap/cover for toxic uranium processing wastes, in an unlined landfill, that become increasingly radioactive for thousands of years.
2. Radioactive materials attributable to the waste materials at the West Lake Landfill have already been detected in the air, groundwater, surface soils, sediments, and vegetation around the site — at or above regulated standards.
3. An underground fire burning in the wastes in the adjacent Bridgeton Sanitary Landfill compromises the cap/cover remedy by increasing radiological emissions and offsite exposures.
4. The radioactive materials in the landfill can be removed and transported to a licensed radioactive waste landfill without unacceptable risk to the public. However, delays in removal will increase costs and long-term exposures to the public.
*U.S. Fire Administration, Topical Fire Research Series, Landfill Fires, Volume 1, Issue 18 March 2001 (Rev. December 2001)”Spontaneous heating is attributed to 5% of landfill fires. This occurs when underground, decomposing waste rising in temperature combusts as it comes in contact with a methane gas pocket. This is known as a “hotspot…”
Evaluation of the EPA Selected Remedy for Operable Unit-1 (OU-1) at the West Lake Landfill
This report provides a summary of observations based on internal communications and recommendations provided by Environmental Protection Agency (EPA) experts in documents published by Agency, including technical experts from the EPA Office of Research and Development, Engineering Technical Support Center (ETSC)1 in 2014 and from the EPA National Remedy Review Board (NRRB)2 in 2013- which was withheld from the public until mid-2016.
Evaluation of the EPA Selected Remedy for Operable Unit-1 at the West Lake Landfill 2 | P a g e
1. The EPA cannot ensure the protectiveness of the cap/cover of toxic uranium processing wastes, in an unlined landfill, that become increasingly radioactive for thousands of years.
a. The EPA’s own experts pointed out the known shortcomings with the proposed remedy design and recommended that Region 7 look into alternative remedies;4
In March 2013, EPA experts from the National Remedy Review Board (NRRB) stated that: “[the proposed remedy] lacked sufficient information on the long-term protectiveness of this alternative.” Furthermore, the NRRB stated: “both of the landfill designs (RCRA Subtitle D and UMTRCA) proposed in the 2008 ROD and 2011 SFS have known shortcomings for handling radioactive waste by itself, let alone handling radioactive waste in a humid region as it would be at the West Lake Landfill.”
The proposed remedy set an unprecedented limit for radiological contamination that was 18 times greater than previously allowed for such wastes located in an urban area.5
The NRRB recommended that instead of enclosing the wastes that Region 7 should excavate the radiological waste and transport it to facilities designed to provide long-term management for such materials.6
The NRRB also determined that the proposed long-term monitoring of the groundwater by itself is not a CERCLA remedy and so could not be a component of the ROD selected remedy.
b. The radiologically-impacted material in the West Lake Landfill is highly toxic and will increase in radioactivity and toxicity over time leading to increased risk to the public;7
The known radiologically-impacted material (RIM) disposed of in the West Lake Landfill is out of secular equilibrium and as daughter products grow back into normal concentrations, the waste materials will increase in radioactivity, toxicity, and risk to the public over time for the at least 10,000 years.
The EPA National Remedy Review Board (NRRB) detailed the dangerous nature of the materials noting, “Based on the package provided to the Board, it appears that there are potentially significant amounts of RIM that are highly toxic (e.g., based on NRC estimates in the 1982 and 1988 reports, radium of up to 22,000 pCi/g, bismuth-214 up to 19,000 pCi/g, and average thorium-230 concentrations of 9,000 pCi/g.” and; “Given the presence of highly radioactive material at this site, and the fact that its hazardous nature will continue to increase over time, the Board believes excavating and/or treatment of any amount of the RIM should lead to important risk reduction.”
The EPA’s cap/cover remedy proposed in the 2008 ROD and 2011 Supplemental Feasibility Study (SFS) does not address the in-growth of radioactivity over time that will occur in the landfill.
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c) The EPA’s proposed cap/cover would not protect the groundwater within and beyond around the landfill from becoming contaminated;
The EPA has not demonstrated that the groundwater can be protected from contamination if the cap/cover remedy as proposed in the 2008 ROD and 2011 SFS is approved. Samples of groundwater at the landfill have found levels of contamination that greatly exceed federal permissible maximum contaminant levels (MCLs) and indicate both the off-site migration of groundwater as well as the potential impact on offsite vegetation.8 9 Exceeding an MCL in groundwater would require a response action according to CERCLA protocol.10,11
The West Lake Landfill is an unlined landfill with no engineering barriers12 in the alluvial floodplain waters that flow into the Missouri River, upstream of the confluence with the Mississippi River. Groundwater levels can highly fluctuate according to rainfall event, and river levels can interact directly with surface water and groundwater runoff near the landfill. Because of the lack of engineered protection at the landfill, groundwater at the site can come into contact with RIM material and spread contamination in the highly permeable alluvial aquifer, and into the deeper bedrock aquifer.
It is extremely difficult to clean up contaminated groundwater. Every available corrective action to prevent groundwater contamination by RIM material in the West Lake Landfill should be considered. As long as the radioactive material remains in the landfill, the groundwater will continue to be contaminated.
d) EPA experts have raised serious concerns with the analysis and characterization of the RIM at West Lake;
In 2013, the NRRB raised a number of serious concerns with “…the way the nature and extent of the RIM at the site was characterized….” The Board pointed out that most of the RIM is located at or near the surface of the landfill (within 10 feet of the surface) as opposed to characterizations made in the ROD and SFS that the materials would be difficult to excavate. The lack of cover materials increases risk to members of the public, because there few if any barriers preventing the migration of radioactive materials and gases from the landfill into the air, groundwater and local environment around the facility.13
The EPA Office of Research and Development (ORD) pointed out that the lack of accurate accounting of the radioactive wastes at West Lake increases the uncertainties related to the potential impacts of the underground fire, at the adjacent Bridgeton Landfill.14
e) Alternative remedies could provide a more permanent remedy protective of the public;
The EPA National Remedy Review Board (NRRB) pointed out that the latest technologies could be employed to sort RIM from Non-RIM materials. The radioactive wastes could be then be sent to a dedicated and regulated radioactive disposal facility,
“Given the presence of highly radioactive material at this site, and the fact that its hazardous nature will continue to increase over time, the Board believes excavating and/or treating any amount of the RIM should lead to important risk reduction. Where it appears that much if not all of the RIM is located near the surface, cleanup at this site appears less complicated than other sites….Radiological material is also easily sorted out in the field with portable instruments that provide instantaneous measurements to ensure that only contaminated material is retrieved which, in turn, minimizes disposal costs.”
Evaluation of the EPA Selected Remedy for Operable Unit-1 at the West Lake Landfill 4 | P a g e
2. Radioactive wastes from the West Lake Landfill have already been detected in the air, groundwater, surface soils trees and other vegetation around the site, at levels above federal permissible Maximum Contamination Levels (MCLs).
Uranium, thorium and their related decay products have been detected in off-site vegetation on private properties around the landfill.15
RIM material has migrated beyond the landfill by surface water transport during strong rainfall events.16
Samples of groundwater at and around the landfill have found levels of contamination that exceed standards.17
Measurements of radon in air conducted for the 2011 SFS found concentrations of radon that nearly exceeded UMTRCA standards.
Levels of unsupported lead have been detected in the local environment around the landfill out of equilibrium with background levels of radon and radium.18
3. An underground fire, burning in the adjacent Bridgeton Sanitary Landfill, could seriously compromise the cap/cover remedy by increasing radiological emissions and offsite exposures.
In December 2010, operators of the Bridgeton Sanitary Landfill detected elevated temperatures and carbon monoxide levels indicating an underground fire was burning in an area adjacent to and connected with known contaminated areas of the West Lake Landfill. The movement of the underground fire in the South Quarry has been unpredictable and there are no estimates of the length of time it would take for the underground fire to reach the RIM in Area 1.
The threat of an underground fire reaching the nuclear waste was of such concern that the Potential Responsible Parties (PRPs) contracted a company called Engineering Management Support, Inc. (EMSI) to prepare a report the potential risks that would be generated if the fire were to interact with the RIM materials. The EMSI report was released to the public in January 2014.
On March 28, 2014, at the request of the EPA, a technical review of the EMSI report on the potential impacts of fire was conducted by the Office of Research and Development – who predicted that an underground fire in OU-1 would:
• Create long-term risks to people and the environment;19
• Limit the effectiveness of the proposed remedy in the 2008 ROD and 2011 SFS, even with a proper cap/cover design, inspection and maintenance;2021
• Increase the temperature and pressure conditions within the landfill, generating large amounts of steam and forcing out a larger volume of gases (including radon) and fine particulates into the local environment;22
• Increase production of contaminated leachate and dissolved gases that can migrate into the groundwater;23
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• Increase potential for releases of radon at levels of concern;
i. Measurements of radon around the landfill for the 2011 SFS recorded concentrations close to Uranium Mill Tailings Radiation Control Act (UMTRCA) standards.24
ii. An underground fire in OU-1 would be expected to further reduce the ability of the waste materials to retain radon gas. By reducing the amount of moisture in the buried wastes, thereby increasing the space between soil particles, more radon will escape;25
• A cap/cover installed over impacted areas at the West Lake Landfill could also hinder efforts to monitor and respond to future underground fire events.26
4. The radioactive materials in the landfill can be removed and transported safely to licensed radioactive waste landfill. However, delays in removal will increase costs and long-term exposures to the public.
Downhole gamma logging and laboratory analyses conducted at the West Lake Landfill reveal that the radiologically impacted materials are generally found at depths ranging between the surface and top 6 feet of topsoil. There are also hot spots of contamination could be targeted for excavation and removal.
In February 2012 the EPA’s National Remedy Review Board (NRRB) conducted its review of the EPA’s Region 7 proposal for remedial action of Operable Unit 1 at the West Lake Landfill. In March 2013, the Board finalized its draft discussions, which concluded
“…based on the fact that the Agency has safely cleaned up numerous hazardous waste sites with radiological contamination across the country, including many in residential areas, the cleanup work can be done safely without unacceptable risk…”
The NRRB recommended that EPA Region 7 should:
“…develop an alternative that reflects an approach which surgically removes the RIM, which appears to be a discrete, reachable source term that will continue to increase in toxicity over hundreds and thousands of years…”
Evaluation of the EPA Selected Remedy for Operable Unit-1 at the West Lake Landfill 6 | P a g e
The EPA has yet to propose a plan for the excavation of highly radioactive materials from the West Lake Landfill, despite their own scientific evidence and recommendations from their own staff experts.
The Federal Government has been removing radiological contaminants from residential and commercial properties for the past seventy years in order to reduce hazards stemming from exposure to members of the public. The removal of radiologically-impacted source material is protective and should be an important objective of any proposed cleanup. These cleanup activities can be safely and efficiently completed with appropriate engineering controls and in accordance with approved health and safety plans.
In the near term, efforts should be made to:
1. Evaluate and implement immediate responses to prevent an underground fire from coming into contact with RIM material;
2. Identify current technologies which could be employed to sort RIM materials;
3. Determine the vertical and linear characterization of groundwater contamination and potential groundwater plume as opposed to isolated groundwater hot-spots;
4. Detect and characterize additional hot spots in the landfill outside of the known contaminated areas;
5. Facilitate the excavation of RIM material from the West Lake Landfill and its shipment and ultimate disposal at a dedicated and licensed disposal facility;
Finally, in accordance with expert evaluations, the proposed remedy in the 2008 ROD should be replaced with a more permanent and protective removal remedy that will reduce hazards to the public. Such a remedy should be developed with feedback from the community.
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Comprehensive Environmental Response, Compensation, and Liability Act of 1980
Engineering Management Support, Inc.
Environmental Protection Agency
EPA ORD Engineering Technical Support Center
Maximum Contaminant Level
National Remedy Review Board
EPA Office of Research and Development
Operable Unit-1
Potentially Responsible Party
Recycled Concrete Aggregate
Radiologically-Impacted Material
Record of Decision
Supplemental Feasibility Study
Uranium Mill Tailings Radiation Control Act
Evaluation of the EPA Selected Remedy for Operable Unit-1 at the West Lake Landfill 8 | P a g e
1 U.S. Environmental Protection Agency, Memorandum, From: John McKernan, ScD, CIH Director, ORD Engineering Technical Support Center (ETSC), To: Dan Gravatt, RPM U.S. EPA Region 7, Subject: Observations on the EMSI report: Evaluation of Possible Impacts of a Potential Subsurface Smoldering Event on the Record of Decision – Selected Remedy for Operable Unit-1 at the West Lake Landfill, Dated January 14, 2014, March 28, 2014.
2 U.S. Environmental Protection Agency, National Remedy Review Board Discussions Regarding the Remedy at the West Lake Landfill Superfund Site, February 28, 2013. (The National Remedy Review Board (NRRB) is a peer review group created to ensure that proposed Superfund cleanup decisions are consistent with Superfund law, regulations and guidance. NRRB members are EPA managers and senior technical and policy experts with significant experience in Superfund remedy selection issues.)
3 U.S. Environmental Protection Agency, Record of Decision, West Lake Landfill Site, Bridgeton, Missouri, Operable Unit 1, May 2008.
4 Comments from NRRB Reviewer John Frisco on PRP Scope of Work: Alternative Cover Designs and Fate and Transport Modelling, “Not sure why an ET [evapotranspiration] Cover is even being considered at this site since its deficiencies have already been identified (Albright and Benson).”
5 Inside EPA, EPA Orders Rare Review of Radioactive Cleanup Plan at Precedential Site, June 28, 2010
6 Internal E-Mail from NRRB Reviewer John Frisco dated February 15th, 2012 stated “Radiological contamination remains active for a very long time and would require long-term management wherever it ends up. For this reason, where possible, we try to send such material to facilities designed specifically for this purpose (e.g., Idaho, Utah). If one could safely and efficiently extract the radiological waste that might be an option worth consideration.”
7 Comments from NRRB Reviewer Charles Openchowski on PRP Scope of Work for groundwater, “The NRC reports also discuss how the toxicity of this RIM will continue to increase over time…this increase in Ra-226 must be considered in evaluating the long-term hazard posed by this radioactive material.” The SFS also acknowledges this fact.”
8 State of Missouri Attorney General’s Office, “Westlake Landfill Tree Core Analysis Report,” Dr. Joel G. Burken, Dr. Shoaib Usman, September 2, 2015 – Scientific data published by the State of Missouri Attorney General’s Office, demonstrated the potential for RIM to transfer offsite. Tree coring analysis conducted around the West Lake Landfill observed elevated radiologic counts of U-238 and U-235 in many of the analyzed samples. These elevated levels indicate offsite migration of RIM into the local environment.
9 Missouri Department of Natural Resources,” Bridgeton Sanitary Landfill Groundwater Investigation Report,” St. Louis County, Missouri, prepared for the Attorney General of Missouri – Analysis of potentiometric contours published by the State of Missouri Attorney General’s Office indicate that groundwater flows in a westerly direction, angling away from the landfill toward the Missouri River.
10 OSWER Directive 9355.0-30, Role of the Baseline Risk Assessment in Superfund Remedy Selection Decisions, April 22nd, 1991
11 OSWER Directive 9283.1-33, Summary of Key Existing EPA CERCLA Policies for Groundwater Restoration
12 Robert E Criss, Risk and Character of Radioactive Waste at the West Lake Landfill, Bridgeton, Missouri, March 14, 2013 – “Specifically, it has no basal clay liner, no plastic sheeting, no internal cells, no leachate collection system, nor any type of protective cap, all of which are standard requirements for modern landfills. Instead the West Lake Landfill is a chaotic pile of debris covered by unmanaged “natural” vegetation, surrounded by a fence with radioactive hazard signs. This landfill is an unsuitable host for any type of radwaste, industrial waste, chemical waste, or even ordinary domestic waste.”
13 Environmental Protection Agency, West Lake Update – EPA to Conduct Additional Sediment Sampling at the West Lake Landfill, May 26th, 2016 – EPA analysis has determined that RIM materials are being transported off-site with surface water after significant rain events and collecting in sediment around the landfill.
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14 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary Bullet Point #2, “Since we do not have a full accounting of the material in OU-1, we cannot make a definitive assessment regarding the potential for chemical reactions between the RIM and non-RIM materials if an SSE (Sub-Surface Smoldering Event) were to occur. If these reactions were to occur, they could cause a rapid buildup of heat or gas, and subsequent reactions or reactive conditions in the landfill.”
15 State of Missouri Attorney General’s Office, Westlake Landfill Tree Core Analysis Report, Dr. Joel G. Burken, Dr. Shoaib Usman, September 2nd, 2015
16 Environmental Protection Agency, West Lake Update — EPA to Conduct Additional Sediment Sampling at the West Lake Landfill, May 26th, 2016.
17 Internal Comments by Charles O. on PRP Groundwater Scope of Work, “Based on information presented to the [National Remedy Review] Board, it appears that there have been some samples of groundwater at this site that exceed standards considered as ARARs…Generally, under existing Agency guidance, exceeding a maximum contaminant level in groundwater normally would warrant a response action.”
18 M. Kaltofen, R. Alvarez, L. Hixson, Tracking legacy radionuclides in St. Louis, Missouri, via unsupported 210Pb, Journal of Environmental Radioactivity, December 2015.
19 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #4, “We do not support the conclusion that no additional long term risks would be created in the event of a SSE at OU-1. There are at least two risk pathways that could exist from an SSE [subsurface smoldering event]. The first is through increased air exposures to contaminants such as radon. As airborne concentrations of radon increase, so would the risk to people. The second pathway is increased leachate production that could move contaminants and dissolved radon gas from OU-1 into the groundwater.”
20 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #2, “…using the higher temperatures observed in the Bridgeton Landfill as a worse-case scenario, these temperatures may cause the structural integrity of the cap called for in the 2008 ROD to be adversely affected. This could potentially include surface cracks and fissures in the cap extending down into the waste material, and potentially cause permeation of the cover used.”
21 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #2, “…if a SSE occurs, short-term risks may be present even with proper cap design, inspection and maintenance.”
22 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary Bullet Point #3, “A SSE in OU-1 would be expected to create increased pressure conditions within the landfill and force out entrained gases, including radon.”
23 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #5, “Short-term effects of an SSE could also include greater amounts of leachate production, which has been observed at the Bridgeton Landfill from condensation of large amounts of steam. An SSE may result in increased emissions of radon and other contaminants in the air and groundwater, even with annual inspections and proper maintenance of designs discussed in the 2008 ROD and 2011 SFS.”
24 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #3, “Given that measurements of radon in air during the SFS were close to a Uranium Mill Tailings Radiation Control Act (UMTRCA) standard, there is potential for radon releases at levels of concern if a SSE occurs in OU-1. This observation does not consider other environmental conditions that could cause radon and other landfill gas concentrations to increase at ground level, such as atmospheric inversions.”
25 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #4, “We do not support the conclusion that no additional long term risks would be created in the event of a SSE at OU-1. There are at least two risk pathways that could exist from a SSE. The first is through increased air exposures to contaminants such as radon. As airborne concentrations of radon increase, so would the risk to people.”
26 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #3, “…a SSE may be present in OU-1 for a long period of time before it is detected, because the only apparent means to detect a SSE after closure is through annual visual inspections.”


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 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” ())·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;::..- • …;.
. : ·;·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~. 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 160
G3 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 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. ~··:
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c 0 06 0 30 0.100 0~0.02 . • . . • .. – 0.03
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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 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
‘ .
• •• 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
‘ .
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,., ‘
. .··
* -··
.· ,.
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. ty on equipment or surfaces shall not be covered
by paint, platinB, or other covering mat eri al unless contumination, 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 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 · .,_. 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 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- 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 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 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 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. 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~) 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. · . \' 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 •
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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 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 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.
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2~ 780
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Co lorado

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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. 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
/ (~ it..H’. ‘”] ., , ‘ ‘ “”!II
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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
: . .. …. – . – — – .
~hank _ ybu for your lett~~ of June 29, 1971. I believe
you 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 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 I the
.financer of t:he original purch.ase 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 . :. _·
· Q\JXrentJs ~ or.~t :~~.\ f.\ t. lh’\nelt~oocl” – ~1issonr1. · ..
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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 ‘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
…….. -.. -·
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 .p.urc.h?Js.c 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.~.·.


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.:· __N_ o_n_c_om_.:.p_l_i<_-_nc_e_ __ ____ ____________ _ _ 7. S'-! 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.
·, 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 t s <• i so cov"'-::~d i~ this •~po·:-t:, a.-:~ iterr.s oe noncorr.;> liance t.;i th
tcv4.~V:-~ 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’ 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 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 f:or this lic€,/~::-;.: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,« Latty Av”nue dead ile storage area
a~d :::-:.: ;no~..:ctioa License Conciiacn 9 S? 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 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• 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~ 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 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 ~> 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 $\lee pet: to pro~e~q 11i t!l the
cleanup of ::::~ -coacibcds.
35. In ~h~ Ciisc’..lssions ~1ith these inC:ividl.lals, i.: vl!s explained that it was
their :aspo~sibility as the licensee, not the responsibility of the s~b-
-.;)n::r<.cto::.:s ( h.:;.~ leo}, to see t'hat this materia 1 was n.ot scattered througiloct ::1-.e unrestt:icted areas. The lice:· .... .:.e stated that they realized t:O:is, .and t:'ley i.' _·e doing every t:!-.~ng they cct:lG to insure that the ~:~ate:-ial haule~s would cooperac~. ~·:censee ;.~aintains recv-rds of the material t:: .·.sported it\ the form of for ~---· · :::\e. vehi.cles. 'Every third veh;;..;:le ht~uling licensee's facility is wcighed0 loaded al\d again empt<::::>~·
~-;.·-., ….. ~ •• ~ :he weight of n:aterial being h.:;.~led on that load. This eveeyn
\ . .. .. ·’
.. .. ef .:
~ 9 –
l’:l~·/h;: at t:.e f ence . lin-a .::·oc.:nd ti1o·.:t vehicle s rcve<~ l c.:; lhoc t he r adiation lP.vel i n the csb oi t:· . .: truck er.d ;:;rou=td the ou\:side of the ve;,icle ~.:as l ess Cl:on 0 .1 mr/hr . Li:>eltise, a survey of the ~,:r.cin~ secu red when ~o<: a tten:lc :>~.:r t~ co'”i> 1~ with that licens-e condition. Y.r. Knockc stated lh<1 t .-:..'.:.:; h~ .:!:'t'l!~ t! t lt3t t.::..:..;.:; otast w wi;~t: the l;.c~:-.43 co~di t ion ctc;ons and that potn~cd out to ~ir. :{:-:.ockc that they ap?ear cci to ba in noncoo?li<:nce t·ri;;h 😮 C7., 20. 20J{c)(2) i n that the sigt>s s::ot~i.:ig the tJo).·ds “Cnution R~di.o:~ctiv e
}:tt e:.:!.cl” tJ~r e not posted around t h~ pcrir.;~ C:er area. in \Jhich ~his i.1<>te~: ial
•.:….::…:::..::.-~-· • – ·- ..;· in t h.s t t’:-,c ~rca <> .:.he t>att’e l stor.,~c .l”:”C,, hod be~~ .
;:;, •• ..$!, ~. ; 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~


1986-04-04 – DOE – Historical Documentation of St Louis Airport Site Material

‘ .>v~-:tt~ Tll l>oE ‘l/Y/’<~ m.o. 1 History of Material Storage at the St. Louis Airport ~torage Site Tnis is a sumnary of tne licensed mdterial that ha' s been stored at the ~t. Louis Airμort Storage Site (SLAPSS). The site is also referred to as the Robertson Airport Site ano as the St. Louis-Lambert Airport Property. The ~1.7 dcre tract is locatea immediately north of the airport, and since l94ti has been used solely for storaye. 1~1ost of tne mater1als stored at tl1e site were resioues genera~ed by tl1e Mall inckroat Cnemical Works during uranium prossessing operations for tne Atomic Energy Co1unission from 1946 to 1953. The t"1anhattan Engineer District (MtO) was grantee consent to use ana occupy the property on Maren 2, 1946; title was acquired by conae1nnat ion proceedings on January 3, 194 7. Table l sumruar i zes the mater i a.1 stored .H. the SLAP$S. Most mat er i a 1 was removed from tne site in tne 1%6 to 1%9 time ftarne, alt11ough some contaminatea wastes were buriea on site. The pitcholende raffinate, AM-7, was a proauct of operations at the 1~1alli11c1y 1~59 as
a result ot operations by MallinciLAt>SS consisr.s of bJried scrap and
wastes. Jecontami nation wastes, n .. t>b I e. and scrap from remov a 1 of bu i: 1j in gs
at Ues tren,rn Street between 195 7 and · %2 are buried at the ·;o1es t end of the
si:e. In aodi~ion, all structures at the SLAPSS ri€re razed in 1969 anu
Duried on site.
Table 1. Materials Stored at
St. Louis Airport Storage Site
Desi gnation
Material fnt ry Inventory Reports
Apri I ‘959 { 1 ) June 1960 (2)
Au9ust 1964 {2)
Uranium Uranium
Tonnage Tonnage Tonnage Tonnage
Pitchblende raff inate
Radium bearing residue
Barium sulpnate cake, unleached
Barium sulphate cake. leached
Colora~o raff lnate
’46 – ’55 (4)
• 46 – • 48 (4)
’46 – ’55 (4)
’46 – ’55 (4)
’46 – ·ss (4)
Vitro residues ’54 from Middlesex
Captured Japanese U,
C-Liner slag
precipitates’54 from Middlesex
Interim residue plant tailings
55,000 30- and 50- gallon drums
steel and alloy scrap
waste, rubble, and scrap
structures on site
’46 – ’53 l5)
begin ’55 (4)
by • 59 ( 4)
by ’59 {4)
bl.Ii l t ’46 – ’59
(1) Reference: Airport Storage Inventory — April 11, 1959.
(2) Reference, Invitations for bids, U.S. Atomic Energy Commission,
St. Louis Area Office, June 10, 1960, and August 3, 1964.
(3) Reference~ U.S. Atomic Energy Comm\ss\on survey, November 1965.
(4) from Oestrehan Street Refinery
(5) from Metal Plant at Plant 4 and Metal Plant 6E at Oestrehan Street
(6) from removal of buildings at Oestrehan Street between 1957 and 1962
(7) to Lake Ontario, New York. storage site
(8) to Cont1nental in 1966, transferred to Latty Avenue, Missouri, and
disposed of at west Lake Landf; 11 by the Cotter Corporation in 1973
(9) portion sent to Fernald In early 19GO’s; remainder to Continental in 1966
(10) buried at west end from 1957 through 1962
(11) razed and buried on site in 1969
——- ——-
74000 113
0 0
1500 22
8700 7
32500 48
350 2
{inc I. in above)
0 0
(inc 1.
1965 (3)
T__o nnage .._ ____
in abovtt)
’66 to Continental
’48 – , 49 ( 7)
’66 to Continental
’66 to Continental
“66 to Continental
’66 to Continental
to Fernald ’59
sold oy ’62
solo by ’62
( 10)
( , 1 )
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CHAPTER 2 ~l/”1′ ti”” ._A_s-re_
SITE DESCRIPTION c_/a’!1~t’f,’CA-r”i-~
4FJ:tM~1)t. ~
The purpose of this chapter is to describe the Latty Avenue
site at Hazelwood, Missouri, the characteristics of the contaminated
soils and structures present on the site, and the local
geology, hydrology and meteorology.
The site is located in north St. Louis County within the
corporate limits of the city of Hazelwood, Missouri. It is on
the south side, and at the western end of Latty Avenue, with a
·street address of 9200. The site is 2 mi {in a straight line)
north and slightly east of the control tower of the Lambertst.
Louis International Airport. The site is part of Lots 11
and 12 of Hazelwood Farm, a subdivision in U.S. Surveys 1 and 2,
Township 4·7 North, Range 6 East, St. Louis County, Missouri.
(See Figure 2-1.)
The total site, comprising approximately 11 acres, is in low
rolling hill terrain at approximately 520 ft above sea level.
It is in the drainage basin of Coldwater Creek, which discharges
some 12 mi downstream into the Missouri River. The variation in
elevation on the gently rolling site is approximately 10 ft. The
site is separated from Coldwater Creek by Right-of-Way lands of
the Norfolk and Western Railroad Company. Figure 2-2 is a descriptive
map of the site vicinity and includes topography of the site.
The site presently is under two ownerships. The westerly
3.498 acres are owned by Mr. Dean Jarboe of St. Louis; he purchased
the property in June 1977 from the Bayliss Company, which
in July of 1976 purchased it from Associate Commercial Corporation,
formerly Commercial Discount Corporation. The remainder
of the site {approximately 7.5 acres) is owned by the Norfolk and
Western Railroad. (See Figure 2-3.)
In early 1966, ore residues and uranium- and raditllll-bearing
processed wastes which had been stored at the St. Louis Airport
fill site, shown in Figure 2-1, were moved by the Continental
(l)See end of chapter for references.
.. “\.’• ..
Mining and Milling Company of Chicago, Illinois to the Latty Avenue
site. These wastes had been generated by Mallinckrodt Chemical
Works of St. Louis during the period 1942 through the late
1950’s. The Commercial Discount Corporation of Chicago, Illinois
purchased the residues in January 1967: much of the material then
was dried and shipped to the Cotter Corporation facilities in
Canon City, Colorado. The source material remaining at the Latty
Avenue site was sold to the Cotter Corporation in December.1969.
Records indicate that residues remaining on the site at that time
included 74,000 tons of Belgian Congo pitchblende raffinate containing
about 113 tons of uranium, 32,500 tons of Colorado raffinate
containing about 48 tons of uraniwn, and 8,700 tons of
leached barium sulfate containing about 7 tons of uranium. During
the period August through November 1970, Cotter Corporation dried
some of the remaining residues at the site and shipped them to
its mill in Canon City, Colorado. By December 1970, an estimated
10,000 tons of Colorado raffinate and 8,700 tons of leached barium
sulfate remained at the Latty Avenue site.
In April 1974, an NRC inspector was informed that the remaining
Colorado raffinate had been shipped in mid-1973 to Canon City
without drying and that the leached barium sulfate had been transported
to a landfill area in St. Louis County. A reported 12
to 18 in. of topsoil had been removed with the leached barium
sulfate. However, analyses of soil samples taken during an NRC
investigati~n of the Latty Avenue site in 1976 indicated the
presence of uranium- and thorium-bearing residues; furthermore,
at some points on the site, direct readings of radiation exceeded
criteria established by the NRC for decontamination of land areas
prior to release for unrestricted use.
On May 30 and June l, 1976 articles appeared in the St. Louis
Post-Dispatch which indicated that there were some discrepancies
in the official records as to how much contaminated material from
the Latty Avenue site had been deposited where. By letter of
June 2, 1976 the Director, Division of Enviromnental Quality,
Missouri Department of Natural Resources, inquired of the NRC
about this matter. During the June 22-24 and August 11, 1976
periods, Region III of the NRC investigated the alleged discrepancies
and reached the following conclusionsC2l:
ft.0.9.QO#Jt 1.W .. tM _ –
(a) About 8,700 tons of leached barium sulfate and
almost 39,000 tons of soil were removed from the
former licensee’s Latty Avenue site and buried
under 3 ft of other soil at the West Lake Landfill
in St. Louis County during the period July-October
{b) The material present at the West Lake Landfill
does not present an immediate radiological health
hazard to the public.
(c) It is estimated that the concentration of natural
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Table l . Uraniwn residues store airport (],> l\1J1… “‘~1” ht
site (November 1965) ~ -J
~~~~~~~~~~~~~~~—“ep”–3v~e ~O
Waste material
Pi tchhlende raffinate > AM,7
Colorado raffinate) /tM—10
11 :>
if l>OO /13
}’21 {oe; 4~
.,.a.~ r\1′”‘f £Barium sulfate cake, unleached
ft’ I i,t)C “”ur
Barium sulfate cake, leached
1,500 22
8, 700 7
(I £Ou t’L
i, t(}(J 7
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Reinforced concrete pit 200 x 42 x 12 ft
Storage shed (concrete flcor) transite roof)
Railroad spur
Loading platform (concrete)
Truck wash pad (concrete)
Thr~e single-story storage shacks (wood)
Chain-1 ink fence
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.,,.,.-~-···~—-~— 90!~•06 … __J _ UNITED STATES GOVE.R NME.N. T
Files DATE: September 25, 1962
R~&-J.-t. ~4>-1/Ul Ronert L. LayfiE91 , Source & Special Nuclear
Materials Branch, Division of Licensing & Regulation
The Contemporary Metals Corporation was awarded a contract by
the AEC fer the removal of uranium-bearin~ residues from stockpile
areas at Rcbertson, Missouri. These residues were generated
by the Comu.ission at its Destrehan Street Plant, St, Loui~.
~issouri. The applicant intends to process tf.ese ~esiile site. In additic:-i to r:.c: .. r::C:s c.f resi..::.;es,
the ?olo!’ad? raffi:-iate ~ unleacl.’ed bari’..:n s~lfc.. e ~~h. ar.d
learlum cake resulting from refinery c~·er~1:1or:s. 2:-:G rn1scellanecus
redc·..ies st~re~ in dr’.,1.-:is. These resic· .. 1es ~·.ave: l:·eer. cx~,c~~<'. the elemer:ts fer several years. The \.later ccr:tei"'.: is esti:r.ate::'. about 15 - 35%. --- ?rocessin p. °? la:"'lt--- };:::zeJwo.a.d • .J:~i ssourJ. _ -·- ---·---- Tr1e ar;ilicant h.S (‘lf lE:::’. situ~. U·~
h s~uth St. Louis. This is an indt:strial zone. i.”n,;:r;; is ~ l2r;-·~
C:.5,0CJ(; feet) steel and concrete factory r:~1ilC.:’..:;;- ~;.::stil’f
aT this site. Th& applicants propose to adept ~his t0ildinf for
t’.ieir specific needs. 7:-,e final facility 1-;i.1..l ~un~:~st cf<'! r.>
pr:::c.r:!”-c:in;::>, are?.• c:·,e::-5 ::.try laboratcry • cha’.’:,-·::: re·,’.”.:”.’. ~;;:! office: .-,~·f:;:;::.
/ ..
The. ComJDission maintains a 21.74 acre residue storage site adjacent
to the St. Louis, Missouri, municipal airport. The site lies
approximately 15 miles northwest of downtown St. Louis. It is
bounded by Brown Road to the North and East, the Wabash Railroad
main line on the South, and Coldwater Creek on the Yest (which is
also the property line of McDonnell Aircra~ Corporation). South
of the Wabash Railroad right-of-way lies Lambert-St. Louis Municipal
Airport and an area occupied by the McDonnell Aircraft Corporation.
Aircraft take-off and landing patterns cross the property. A location
map is attached as Exhibit 1. An aerial photograph, .Exhibjt 2.
locates the site with respect to adjoining property.
The site is completely fenced; there is a roadway access gate on the
North-side and a railroad gate on the South side, allowing ffabash
iailroad service to the pl.ant via a spur line off the main line
track. The complete area, with its mounds of raffinate residues,
stacks of drums, hodge-podge of. scrap alld temporary type structures,
has the appearance of a. typical spoil area common to chemical
indu~tries having residue storage ptoblems.
Consent to use and occupy the tract was obtained by the Manhattan
Engineer District on March 2, 1946. Title was acquired to the
property on January 3, 1947, by condemnation proceedings for
$20,000. The property was acquired for the purpose of storing
residues from the Destrehan Street Refinery and the Metals Plant.
The major capital improvements to the site were a concrete pit,
202 ft. x 42 ft. x 16 ft., constructed to store radium-bearing
residues (though it vas never used for this purpose), a covered
concrete pad 45 ft. x 250 ft. for the storage of drummed materials
and a railroad siding with loading tipple. A detailed description
of the structures on site is given a·s the last section of this
The site vas operated by the Manhattan Engineer District and the
Commission from 1946 until J1.11y 1953, when the operation was
turned over to Mallinckrodt Chemical Works. Guards vere maintained
at the site from 1946 to 1951.
The Destrehan Refinery started operations in 1946, utiliiing
pitchblende ores and continued on this. feed until early in 1955.
– 1 …
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! ·:
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~. ……… -,–“‘·-·~·-·—-··—.-.- ..- ·–~·–…—-·~———~——-·—-·-·-·~ -~—— –~—-··· ….. i
The procurement contract for these ores with African ~tals
Corporation required the United States to store both the pitchblende
raffinate (AM-7), which contains metal values other than uranium,
such as nickel. cobalt, and copper, as vell as the radium-bearing
residues (K-65)t as African Metals retained ownership of all
material excepf .its uranium content. African Metals. subsequently
transferred ownership of the AM-7 raffinate to the Government.
A large concrete pit was constructed to store the radium-bearing
residue (K-65) but was not used for this purpose due to health
reasons. Instead, this residue was stored in druDlS at the site,.
from 1946 until early in 1948. It was then transferred to the Lake
Ontario Storage Area, Model City, Nev York, in 1948 and 1949. lhe
AK-7 was stored on the gro~d in the open where it remains today,
except for about 350 tons of pitchblende raffinate (AM-7) which were
processed in a small pilot plant facility at Destrehan Street to
recover ionium. This material was processed in 1955-1957 and
returned to the originf 1 raffinate storage at the site.
The raffinate (AM–10) produced from subsequent operations using nonpi1chblende
feeds was stored separately. A barium cake residue
(AJ-4) produced by the refinery is also stored at the site; this
residue resulted from the precipitation of digest liquor with barium
carbonate to reduce its sulphate content. Both of these materials
are stored on open ground.
The residues generated by the refinery aggregate to greater than
95% of the material present~ stored at the Airport Site.
The other major components of residues were generated as slag from
the reduction step of the metal operations at Destrehan Street.
Two types of this material have been generated. Initially the
reduction. bombs were lined with dolomite. The used dolomite liner
(C-liner) was shipped from Destrehan Street and stored at the Airport
Site in bulk on the ground. Shipments of the dolomite slag started
in March 1946 and continued until early in 1953 when the dolomite
liner was replaced by a recycle magnesium fluorine liner. Approximately
half of the C-liner has since been shipped to FllPC for
recovery of the uranium content.
In 1955 an Interim iesidue Plant was constructed at Destrehan Street
to scalp the uranium content from the magnesium fluoride slag produced
in the Metals Plant. tailings from this operation (C-701)
were stored in the concrete pit at the Airport Site, and since have
alt been shipped to FMPC for recovery or the contained uranium.
By 1960 there also had accumulated at the storage site approximately
50,000 empty drums and 3500 tons of contaminated steel and alloy
scrap. However, by 1962 the bulk oi these materials bad been disposed
of for the metal salvage values.
– 2 –
‘ .
.r • t .
……….. -………. –·- —.–…·- … — …………….. ·-·—·
Approximately 2400 drums remain in the area; these c~ain aisc•l·
laneous residues, Japanese uranium-containing send and contaminated
scrap materials.
Haterbl presently stored at the site is stamnari.zed belcnn
Gross Tons Approx.Tons U
Pitchblende Raffinate (AX-7)
Raffi.nate (A.K-10)
Barium Cake (AJ-4)
Other Miscellaneous Residues
· and Captured Japanese 1J
C-liner slag
The original ground purchased in 1946 was Vf!ry uneven· and contained
• low drainage area on the western section of the site. The land had
a drainage slope from East to West, with all surface drainage directed
to the Coldwater Creek at the western edge of the property. The
initial topography of the site is shown in the aerial photograph,
Exhibit 6.
It has been extremely difficult to ;econstruct precisely the sequence
and location of contaminated materials and residues deposited on site.
The Committee has collected from various files and from McDonnell
Aircraft Corporation a series of aerial photographs which depict the
transition at the original site to its present state. Various reports,
drawings and sketches were also located which contributed to a general
understanding of the degree of contamination of the site. Numerous
individuals associated with the Airport Storage Site have been contacted;
however, since such a time has lapsed since the active
operation of the site, much or the information obtained by these
verbal inquiries is qualified by uncertainties of memory. .Also, many
of the people who were intimately associated with the site during
its early operation are no longer available.
Judging from the knowledge gleaned from the above sources, it appears
that with respect to the western part of the site, early dispositions
of contaminated scrap metal were located in the lov areas then existing
on the western end of the property. The scrap metal and other
debris were later covered (in 1952} with dirt received (gratis) Crom
McDonnell Aircraf’t Corporation and worked with heavy equipment to
make a level storage area (see Ex.hibit 7). The reclaimed area is
nov occupied by AM-10 raffinate, drums of Japanese sand and contaminated
rubble and other waste from Destrehan Street •
• 3.
.f ,,~
:·{: L ~

. :· .’.
The existence or buried contaminated metal below the present surface
of the western section of the site was confirmed by tes,t drilling
described elsewhere in this report. Underground contaminated scrap
ia reported to be on the order of magnitude of 50 to 60 truckloads
plus one contaminated vehicle.
The eastern two-thirds of the site presently is covered with mounds
of C-li.ner slag, raffinate (AH-7)> and barium cake (AJ-4). These
mounds of residue rise to approximately 20 feet above normal ground
level. Drainage from the mounds and the adjoining areas is directed
to the Coldwater Creek •
.Drainage waters from the storage area have, in the past, produced
some minor contamination in Cold~ater Creek. Continued monitoring
of the complete area and the creek waters, however, has indicated
that significant levels have never been reached and that all radiation
readings are well within permissible and acceptable limits presently
prescribed by .AEC directives and manuals.
A topographic survey map of the site (Exhibit 3) shows the existing
limits of residue stockpiles, the general topography of the remaining
area on the basis of one root contour intervals and the location of
principal structures at the site. The aerial photograph, Rx:hibit 4,
shows the site essentially as it exists today.
The area is iDclosed by a chain link fence. It c.ontains the folloving
A reinforced concrete pit consisting of floor slab and walls,
200 ft. long x 42 .ft. wide by 12 f’t. deep.
A storage shed consisting of a 250 ft. x 45 rt. concrete floor
pad, with a center wall 7 ft. high and 1 ~- thick running the
length of the structure. The pad is covered with a corrugated
metal roof supported on wood columns and trusses. Sides and
ends of the shed are open.
A single track railroad spur which enters the south fence near
the east end of the site.
A steel and wood· tipple is located along the spur.
A timber drum loading platform, 18! ft. x 8 f’t. x a!- ft. high,
with stone fill ramp, is located just east of the tipple.
A reinforced concrete wash pad for trucks, measuring 51! ft. x 3Si rt. is located east of the Storage Shed.
1 l
• • ) • •
– —·-~-~—– …. d d -·-·—_……._ -~- — ·-· ·—~—. ·-· ·-· .. ··-·—·-··—‘—-, I \C

A reinforced concrete truck loading platfonn with tamp is
1.ocated north of the vash pad and adjacent to the vest end
of the Barium Sulfate residue. It is T-shaped, measuring 24 rt.
long x 65! ft. vide at the north side x la:l ft. vide at the
eouth si~e.
Three single-story wood buildings are also located. on the sites
A 32 ft. x l&i rt. office building at the main gate
on the north side of the area.
A 24j- ft. x 12 ft. guard house also at the main gate •.
A 9 rt. x 7 ft. portable guard house located near
the south fence, midway of the property.
– 5 –
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History of Material Storage at the
St. Louis Airport Storage Site
This is a sunrnary of the licensed material that has been stored at the
St. Louis Airport Storage Site (SLAPSS}. The site is also referred to as
the Robertson Airport Site and as the St. Louis-Lambert Airport Property.
The 21.7 acre tract is located immediately north of the airport, and since
1946 has oeen used solely for storage.
Most of the materials stored at the site were re$idues generated by the
Mallinckroat Chemical Works during uranium prossessing operations for the
Atomic Energy Conrnission from 1946 to 1953. The ~anhattan Engineering
District was granted consent to use and occupy the property on March 2,
1946; title was acq~ired by condemnation proceedings on January 3, 1947.
Table 1 summarizes the material stored at the SLAPSS. Most material was
removed from tne site in the 1966 to 1969 time frame, although some
contaminated wastes were buried on site.
The pitchblende raffinate, AM-7, was a proouct of operations at the
Mallinckrodt Oestrehan Street Refinery, which used pitchblende ores as a
< ·, feed for uranium production from 1946 until early in 1955. These ores were purchasea from African Metals Corporation, with the contract requiring the U.S. to store the raffinate while African Metals retained ownership of all mater1als other than uranium. The raffinate was storea in bulk on the grouna. About 350 tons of tHe ~-7 were processed in a pilor· plant at Oestrehan Street to recover ionium from 1955 to 1957, and returned to storage at SLAPSS. African Metals abandoned the material fol1owing aecreases in the market values of the nickel, cobalt, and copper remaining in the raffinate. The ~-7 was part of the residue from the site sold in l~ti6 to Continental Mining and Milling Company, and was moved to the Latty Avenue site from 1966 to 1967. ~ fo_, Radium bearing r~dues K-65, were also owned by African Metals and stored at the site~ Storage was originally planned to be in the concrete pit at the site, but due to health reasons was stored in drums. It was transferred to the Lake Ontario storage area in 1948 and 1949 • j ... ·.·· . Barium sulphate cake residue. AJ-4. was another product of the Destrehan .· Street Refinery. Storage was in bulk on the ground. _African Metals ~r e~I relinquished ownership of the barium cake. also referred to as airport .. ..,,... cake. It was part of the resiciue solo to Continental in 1966. The 8700 ..t- ~"''fl' tons of leached barium sulphate cake were believed to be dumped at the West ~~'wJ Lake Landfill by its owners. the Cotter Corporation, in 1973. However, c ,,.. t...,. .~( traces remained at the site, and were removed and disposed of at the Weldon _.. r1·"" Spring quarry in 1969 by the St. Louis-Lambert Airport Authority. .,.. .. _~-' Oi-t>~ \)
+ ~’ “”· .. , ..
The AM·lO raffinate was a re~idue resulting from the processing of C\. “,. ., ,v-‘i·,·~·
aomestic ores at Oestrehan Street. It was stored in bulk at SLAPSS~
separately from the AM-7. It was part of the residues sold to Continental
and removed in 1966-67.
‘-‘• “·”‘”””
Other residues which were presumably sold to Continental were the C-6
Vi!tro residues and V- lO capturea Japanese uranium-containing sands and
precipitates. These materials were stored in drums. They were transferred
to the SLAPSS from Middlesex in 1954 during th~~~loseout. w~
The C-Liner slag consisted mainly of dolomite liner with less than 2%
uranium content, and was stored in bulk on the ground. It resulted from the
sepdration of slag from the reduction step in the Metal Plant at Plant 4 and
later in Metal Plant 6E at Oestrehan Street. Shipments began March 10* 1946
and laste~ un~~~,!~jJY 1953 when the dolomite liner was replaced by a
re~~r~lnvento~y as of April 11, 1959 showed 7,800 tons of
C-Liner slay containing ~22.3 tons of uranium. A portion was sent to
Fernald for processing in the early 1960’s; inventory as of November 1965
was 4,000 tons containing 49 tons uranium. The remainder was transferred
to Continental in the 1966 sale.
The interim resiaue plant tailing~were from operations at the Destrehan
Street site, which conrnenced in 1955 to scalp the uranium content from the
magnesium fl~rioe slag. The tailings were shipped to Fernald and processed
in the late 19SO•s. with the process rate increasing to about 600 tons per
month in July 1959. ~ , ~ ~ /~d- fG.J ~A
;…… “~ ,q,(“~.d). ~ ~. J ~. . .
l \
:. : ~.” :•. ·.. ‘
… · ..
remainder were disposed, to
and alloy scrap. 1\ . .!~ 4 .. , ‘- •· · .J_ ·; ‘t-~;.t-,/~ ~~v . .:-. ,
~ “r ~ °”‘” ll.U. 4-JJ.. , ,.. ./ ‘ sf.~ . ‘~/ r~.J…c,t~ A . … • ….1.
The only material remaining at the SLAPSS consists of buried scrap_. ~·
Oecontarnination wastes, rubble, and scrap from removal of buildings at
Oestrehan Street between 1957 and 1962 are buried· at the west end of the
site. In addition~ all structures at the SLAPSS were razed in 1969 and
buried on site •
. .
‘f~ tlv-t …. ~~~ ~::::’~ .s .. &.
_.,… .. —··· ···~··
N ;f ~ ··…A ~ SA- La. – ~ S A ( t -i 6 6 ) .( ~I e. l . ._._
ft, t.-Lf i.,._o…1.. \.-o ~ llO ·.J ·r,., –i Tic …. ~ k ~ -vi (,,, k ……._
;~ l •. L.._,_. ~:;> t…1 ·~ .• /-c-. s-./’~ – 7 ~-,,. ··IA.~ /,-;- ::- -~~
. I ~ ~
‘1A I I f’• ,._sl.. ,_.!/
……. -·– —-~·– …
s~ ~J F ~ ,._ fi .’vr-J ~~ –
e.I. ff~ – w <-~~/Iv J J5 ~ r< (4)",J.1,..,... 4 ... . ....... I . :3' :·:_,_ ...


2016-02-19 – EPA – Pb210 by Gamma LEPS Data- Enformable Latty Ave sample- Eberline 16-01135

Safadi, Amer[]; Vann, Bradley[]
Juett, Lynn
Sent: Fri 2/19/2016 5:14:16 PM
Subject: RE: Pb210 by Gamma LEPS Data – Enformable Latty Ave sample – Eberline 16-01135
From: Safadi, Amer
Sent: Friday, February 19, 2016 10:52 AM
To: Vann, Bradley
Cc: Juett, Lynn
Subject: RE: Pb210 by Gamma LEPS Data – Enformable Latty Ave sample – Eberline 16-01135
From: Vann, Bradley
Sent: Friday, February 19, 2016 10:36 AM
To: Safadi, Amer
Cc: Juett, Lynn
Subject: FW: Pb210 by Gamma LEPS Data – Enformable Latty Ave sample – Eberline 16-
WLLFOIA4312 – 001 – 0015820
From: Doster, Branden•=.:==~=~==”‘-‘=~~=”-“-•
Sent: Friday, February 19, 2016 10:32 AM
To: Evans, Erin ‘’
Garoutte, Jonathan
Mahler, Tom
Cc: Vann, Bradley Schmidt, Aaron
Juett, Lynn
Subject: RE: Pb210 by Gamma LEPS Data – Enformable Latty Ave sample – Eberline 16-01135
WLLFOIA4312 – 001 – 0015821
From: Marco Kaltofen t:..==~====~==-‘-”
Sent: Thursday, February 18, 2016 3:39 PM
To: Taylor, Shantell
Cc: lhixson; Robert Alvarez
Subject: Latty Avenue Site – New data from Eberline Laboratory
Dear Ms. Taylor,
You may recall that a couple of weeks ago we spoke about a particularly high activity sample we
collected in our study of radioactive materials related to the West lake Landfill in the St. Louis
area. We have accumulated further data on this sample. It is our believe that it would be more
protective of the public health to provide your office with these data immediately, rather than
wait months for scientific publication.
I have attached the interim data report from Eberline Laboratory of Oak Ridge, TN. Eberline is
performing an analysis of this material on our behalf. (See attached Excel file number 06-01135)
This work is part of our follow-up to our recent study published in the Journal Environmental
Radioactivity (attached).
The sample was collected in the railroad spur area adjacent to Coldwater Creek at Latty Avenue
in Hazelwood, MO. As you can see from the attachment prepared by the laboratory, 230-Th
activity is 10,923 pCi/g. Total Uranium activity in this sample is 854 pCi/g, with an enrichment
level for 235-U of 4.1 %, which is about average for civilian grade nuclear fuel materials. The
total sample activity is 320 KBq/kg (320,500 Bq/kg). These numbers are very significantly
elevated above all pertinent environmental standards.
We also have a great deal of back up data for this sample. In particular, the microscopic analysis
shows that the material contains respirable particles with 10 to 46 % by weight pure uranium.
Three of the files labelled Latty, particle 4, show examples of this microscopic analysis.
Given the elevated activity of the sample in this location, we would like to get a copy of this data
to the Corps of Engineers office in St. Louis. If you prefer that the COE get any notice directly
WLLFOIA4312 – 001 – 0015822
from the MO AGO, that is more than acceptable to us. If not, if you have a preferred contact at
the COE, we would be happy to send the information directly.
Please let me know if you have any questions about these data.
Very truly yours,
Marco Kaltofen, PhD, PE (Civil, MA), C. NSE
Boston Chemical Data Corp.
2 Summer Street, Suite 14
Natick, MA 01760
Affiliate Research Engineer
Nuclear Science and Engineering Program
Dept. of Physics
Worcester Polytechnic Institute
cell. (508) 259-6717
office ( 508) 314-9334
cc: L Hixson, R. Alvarez
WLLFOIA4312 – 001 – 0015823
This email message, including the attachments, is from the Missouri Attorney General’s Office.
It is for the sole use of the intended recipient( s) and may contain confidential and privileged
information, including that covered by§ 32.057, RSMo. Any unauthorized review, use,
disclosure or distribution is prohibited. If you are not the intended recipient, please contact the
sender by reply email and destroy all copies of the original message. Thank you.
WLLFOIA4312 – 001 – 0015824


1969-01-16 – AEC – Response to Cotter Request to dispose of Barium Sulfate Residues at Weldon Springs

P-0. BOX E AREA CODE 6,5 [
“JAN 16 1969 . i
Mr. Warren E. Goff
Mining Engineer
Cotter Corporation
Post Office Box 751
Canon City, Colorado 81212
Dear Mr. Goff:
Reference is made to your letter dated October 1, 1968, requesting
permission to dispose of approximately 2,500 tons of spent Barium
Sulfate at our Quarry Site near Weldon Spring, Missouri.
Justification, sufficient to grant the permission requested, does
not appear adequate at this time. Currently, the AEC has no operations
at Weldon Spring and would be uninterested, therefore, in adding to
our limited existing surveillance responsibility at the site. Should
the Cotter Corporation continue to have an interest in the pit stored
raffinates at the Weldon Spring Plant Site, as you have previously
indicated, we would be happy to reconsider and evaluate any mutually
beneficial proposal you might wish to offer.
If we can be of further assistance in this or other matters do not
hesitate to call on us.
R. Sapirie az
Manager ‘
OSH:WTT Oak Ridge Operations *»
cc: R. C. Armstrong
C. A. Keller _,
C. W. Hill . e,
J. A. Lennard

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