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

Page 1 UPDATE ON WESTLAKE LANDFILL NOV J 7 HISTORY OF WESTLAKE LANDFILL Westlake Landfill, located... View Document

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1980-10-02 – MDNR – West Lake Landfill – Memorandum – History of Operations

MEMORANDUM
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Date: October 2, 1980
Jo: Bob Schreiber
From: Burt McCullough
Subject: Westlake Landfill
Westlake Landfill, located in Bridgeton Missouri (St. Louis County) has been
the subject of recent inquiry. This landfill began operation prior to state
regulation. As far as our records show, this landfill first opened in the
mid-1960’s. Part of the landfill lies in an old quarry and part of the landfill
lies in the Missouri River floodplain, approximately 1^ miles from the
river. Witnesses to this operation, when the area of the landfill which lies
in the floodplain was in operation, note that the fill area was often actually
beneath the level of the water table. According to file materials from
Missouri Geological Survey, it is “highly probable that leachate from the
landfill is entering the waters of the Missouri River. . . ” Leachate from
the old quarry area of the landfill is collected and hauled to MSB treatment
plants. Construction of onsite treatment facilities is underway. About 48,000
gallons of leachate per day is currently being collected.
Aside from normal landfill materials, there are chemical industrial wastes and
radiologically contaminated materials deposited in this landfill. The chemical
wastes, that we know of, include about 4,000 tons of residues from the production
of insecticides and herbicides. These pesticide wastes were deposited by
Chevron Chemical Company. Also included in the chemical wastes are waste
materials from ink manufacture and from the manufacture of glue. Among the
chemical wastes that we know of in Westlake Landfill are:
waste ink pigments
esters alcohols
halogenated intermediates
oils wastewater sludges
heavy metals asbestos
oily sludges
insecticides
aromatics
herbidices
Joseph
Fred A
Besides chemical hazardous wastes, in Westlake Landfill, there are radioactive
wastes. During early 1973 Cotter Corporation buried radioactive Barium
Sulfate Slag material and radiologically contaminated building rubble. There
are approximately 9,000 tons of this material which contain about 7,000″tons
of natural Uranium. In October, 1977, an aerial radiological survey was done to
determine the location of the burial of this contaminated material. The report
from this survey indicates that there are two burial sites. One is in the
center of the old quarry area, and the other is on the edge of the floodplain
area which borders adjacent farmland. The U.S Nuclear Regulatory Commission
has contracted Radiation Management Corporation to do extensive on-site
radiological surveys which include groundwater analysis, core sampling, test
boring, and other tests as deemed necessary. The NRC has given DNR verbal
P. Teasdale Governor Division of Environmental Quality
Lafser Director Robert J. Schreiber Jr., P.E. Director
Westlake Landfill continued
Page 2
October 2, 1980
To: Bob Schreiber
permission to utilize the monitoring wells which Radiation Management
Corporation will be digging, in order that DNR may test for the presence of
chemical hazardous wastes.
There is little known about what went into Westlake Landfill prior to State
regulation. Analysis needs to be done to determine: 1) what wastes are
deposited in Westlake Landfill, 2) if any of these pollutants are leaving
the landfill via groundwater, and 3) what threat does Westlake Landfill pose
to drinking water supplies.
cc: Fred Lafser
Ron Kucera
Jim Long
Robert Robinson
Bob Miller
Tom Doan

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

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MEMORANDUM
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SEP 2 5 1980
SOLID
Date: September 25, 1980
To: Robert J. Schreiber. through Richard F. Rankin
From: Burt McCuiiough
Subject: Westlake Landfill
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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
40056883
SUPERFUND RECORDS
Joseph P. Teosdale Governor
Fred A. Lafser Director
Division of Environmental Quality
Robert J. Schreiber Jr., P.E. Director
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1980-01-15 – MDNR – Concerns related to West Lake Landfill

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Mr. W. T. Crow
Office of Nuclear Materials
Safety and Safeguards
Nuclear Regulatory Commission
Washingtoii, D.C. 20555
Dear Mr. Crow:
This letter will confirm our telephone conversation of January 7,
1980 concerning the Westlake Landfill. I’m attaching to this
a copy of my Decrmber 31 letter to Mr. Earl Harvison, Oakridge,
Tennessee.
I would appreciate your early response to the questions raised
in that letter. I’m also attaclng a copy of the resolution
submitted by the Lity of Bridgeton to us in this matter. If we
can be of assistance to you, please let me know.
Very truly’ yours,
,eJames P. Odendahl
Director
Division of Environmental Quality
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cc: Senator Edwin Dirck
Keii Mille-. Dept. of Health
Solid Waste ,nagement Program
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PDR FOJA
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Joseph P. Teasdale Governor
Fred A. Lafser Director
Division of Environmental Quality
James P. Odendahl Director
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December 31, 1979
Mr. Earl Harbison
Departmcnt of Energy
Oak Ridge, Tennessee 37830
Dear Mr. Harbison:
Please find attached my letter of response to the City of Bridcet.cn
regarding their resolution relative to the disposal of radic..:tiýe
waste materials in the vicinity of the city. Mr. Rick koberts, with
the Department of Natural Resources, Solid Waste Mariagement Program,
is been in telephone comniunication with you during recent months
requesting that your office provide us with the res,:lt, of the
technical study which was conducted to determine the l.)cation ana
levels of radiation emitting from the wa;te disposed of at the
Westlake Land’ill in St. Louis County. This aerial survey of th’e
Westlake Landfill and other areas in the St. Louis Couity was cocducted
at least a year ago. The Department of Natural R_:scurces
would appreciate this information being made available in order that
we can assess the potential public health effects.
If there are reasons why the study cannot be released to the
Department of Natural Resources, I would appreciate teinc, so advisec.
Sincerely,
James P. Odendahl
Director
Division of Environmental Quality
JPO/RMR/jc
Encl.
Joszph P. Teasdale Governor
Fred A. Latser Director
Division-of Environmental QualIty
James P. Odendahl Director
December 28, 1979
IL llonorable E. I’J. (Bill) Abram
Mayor
tv ) City of Bridgeton
11955 Natural Bridge Road
0 Iq Bridgeton, Missouri 63044
cV) “-” Dear Mayor kram:
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0 Senator Edwrn L. Dirck ha, forwarded the City of Bridgzton’s Resolution
0_ R-79-12 relative to dispo:.al of radioactive material to the Department
of Natural Resources for response relative to Missouri’s role in control rr
the disposal of radioactive waste materials.
0
D • You are probably aware that the Federal Nuclear Regulatory Commission ha.,
< the primary responsibility for controlling the disposal of radioactive < • waste materials. The State of Missouri is not an agreehient state and U his no arrdnrements with ithe Nuclear Regulatory Cormission to enforce th, C re2gulatioe• within the Stdte of Missouri. At the pres2nt time the Solid 0 ý2iste Regulations of the Department of Ndtural Resources prohibit the 2 acceptance of radioactive v..a=-te materials at permitted sanitary landfill,. The:'eforL, the Westlake L.inc-fill in St. Louis County does nut have autno z ization to arcept radioactve waste materials. The Department of Nature _2,ources is interested in %..hat radioactive waste materials maý have be(: di, pcsed of -.t the Westla'e Landfill in the past and has been in corurinni - cat-on with the Departtmen. of Lnergy in Oakridge, Te!nnessee requestinc 3)- tiat they privide us with wiiat informaL ion they liiv c..btained relitt'e Q 2 tie dispoual of the waste at the 4estl (4e Landfi 11. 'r. Earl Harh iscn <• > .with the Leý…tinent of Eneýrgy has assured us he will provide us with a c
‘0 ,of the inves.iaation repo-t ,.s soon as it is availaiii(.
0 It has been indicated triat ,,’ry lo.i lev, 1 radioactive ,.*,,te materiai w-.
involved in :he disposal it the Westlakc Landfill, an( there should he ‘;
rV danijer to th.. citizens of i;ridjetor., lh. ,;ver, th; :)e( artment of Na’.uro 1
-o e’,uurces wa:its to revieq -i .uccnni’aý djt, fro,- tCie ili’partment of z:iV 6C) in/vstigatici, and stuJy b2 “e makinj .1i v recorw-nd~tt ins as to wha..
;nruld be talen.
U~) CC
Joseph P. Teasdale Governor .Divisiion o? Enviror’m .’al (ucij’y
Fred A. Lafser Director James P. Odenclani Dirzcior
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NJISSOUJUl SEX’A’rE
j K; FIVF I.JIYO.* GI Ty
.EzDWv r L. D jRcI.&
SINATOR, 24TH DIscrIC
CAPITOL IUILDINO
.ILFFEP60N CITY. MISSOURI 69101
TELEPHOMNE 1314) 721.2540
November 8. 1979 1074t. ~l.
TEL.IPM~N’. ill
Mr. James Odendahl, Director
Division of Environmental Quality
P. 0. Box 1368
2010 Missour- Boulevard
Jefferson City, Missouii 65101
Dear Mr. Odendahl:
Attached please find a copy of a letter and rcz3c
lution that I received from Mayor bill Abram of
the City of Bridgeton, St. Louis County. Although
I realize the Nuclear Regulatory ‘Commission has
responsibility for disposal of radioactive waste
materials, I would appreciate your responding to
Mayor Abram and advising with regard to Missouri’s
role, if any, in this area.
Thanks for your help.
Sincerely,
Ewi
Edwin L. [Dirck
ELD:1s
Enclosures (2)
IF A 4 OF
CITI Y OF 1R1I[)G F-TON
Octobor 33, 1979
E.W. (1:111) AIJRAM. Mayor
M.AR T, Ili(. COF-CRAN. Admrimisttstivo Asis~sant
MARY E:.O E LLfRIMANN. City I
honorable E&.Ain L. Dirck
Stite Capitol ‘ld,).
Jefferson Ci:y, Mo. 65101
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(Oear Senato Di rck:
T~he City Co. rcil at its r…t’g of h’tcji)er- 24. H-79, ýass2d tf’e
crlclcsed Reclutien P-79-12, which I (iree with aid ,s of great
cencern to the residents of thre City of 3ridgeton.
fAry help )’:u can give in 1lis matter Wi II be gret ly appreciat,:.d.
Sincerely,
E. B4i( B1lAblra)m ., Mayo
EWA tp
E~ncl osure

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1988-10-25 – MDNR – West Lake Landfill – Letter to EPA requesting determination of Hazard Ranking Score

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DuiMcin ol I mironnu-m.il Otulii
UIVIMOM ,,| („…,!,w jnj |J1Klsi,n
FREDERICK A. BRL’NNKR “”X” “”VM-m ,» M.in^-tm-m x-rvuvi)
irix.t,,r STATI: (>i MI>S(>riu nm>i,,n ,,f |.arkv R^…^,,,,.
DEPARTMENT OF NATURAL RESOURCES “” “1N”W”””Jllim
Di\’isioN OF I:NVIRONMI;NTAL gi’Ai.nv
I’.O. Box 176
Jefferson City. MOdSI()2
October 25, 1988
Mr. David Wagoner, Director
Waste Management Division
U.S. EPA Region VII
726 Minnesota Avenue
Kansas City, KS 66101
Dear Mr. Wagoner:
The U.S. Nuclear Regulatory Conmission (NRC) staff recently released
a report (NUREG-1308, June, 1988) on the radioactive wastes at the
Westlake Landfill in St. Louis County, Missouri.
In the report the NRC staff concludes that “(1) measures must be
taken to establish adequate permanent control of the radioactive
waste and to mitigate the potential long term impacts from its
existing storage conditions and (2) the information developed is
inadequate for a determination of several important issues, i.e.,
whether mixed wastes are involved, and whether on-site disposal is
practical technologically, and, if so, under what alternative
methods.” However, the report does not indicate whether the NRC will
take any further action at the site and informal communication with
the NRC staff indicates that NRC does not intend to take further
action.
The suggestion has been made by a number of state and local officials
and citizen’s groups that the U.S. Department of Energy should
undertake action at the site under the Formerly Utilized Sites
Remedial Action Program (FUSRAP). However, a letter from DOE was
received by the Missouri Department of Natural Resources on
October 30, 1987 which states that [‘the DOE has reviewed the
possibility of the Westlake Landfill being designated as a FUSRAP
site and has concluded, based on the criteria used to designate
FUSRAP sites, that the Westlake Landfill is not eligible for
consideration as a FUSRAP site. The radioactive waste was under
Nuclear Regulatory Commission license when it was brought to the
landfill and, consistent with current DOE policy, would not be
disposed of at a DOE site.”
Mr. David Wagoner
October 25, 1988
Page 2
Since no further activity is planned at the site by either the NRC or
the DOE, I request that the U.S. Environmental Protection Agency
(EPA) determine the Hazard Ranking Score (HRS) for this site and, if
appropriate, place the site on the National Priorities List (NPL).
This ranking should be conducted using all currently available
information on the site. Further, I request that EPA initiate the
Superfund process to determine potentially responsible parties and,
if necessary, initiate enforcement action to begin an appropriate
remedial action.
The Missouri Department of Natural Resources believes that the
current uncontrolled condition of the radioactive waste at the
Westlake Landfill is unacceptable and we are interested in expediting
action at this site. Please contact me if you have any questions
regarding MDNR’s position on this matter.
Sincerely,
DIVISION OF ENVIRONMENTAL QUALITY
William C. Ford/Director
WCF/dbc
cc: Mr. Jim Fiore, DOE
Mr. Germain LaRoche, NRC

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1980-10-02 – MDNR – West Lake Landfill – Memorandum – History of Operations

MEMORANDUM
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Date: October 2, 1980
Jo: Bob Schreiber
From: Burt McCullough
Subject: Westlake Landfill
Westlake Landfill, located in Bridgeton Missouri (St. Louis County) has been
the subject of recent inquiry. This landfill began operation prior to state
regulation. As far as our records show, this landfill first opened in the
mid-1960’s. Part of the landfill lies in an old quarry and part of the landfill
lies in the Missouri River floodplain, approximately 1^ miles from the
river. Witnesses to this operation, when the area of the landfill which lies
in the floodplain was in operation, note that the fill area was often actually
beneath the level of the water table. According to file materials from
Missouri Geological Survey, it is “highly probable that leachate from the
landfill is entering the waters of the Missouri River. . . ” Leachate from
the old quarry area of the landfill is collected and hauled to MSB treatment
plants. Construction of onsite treatment facilities is underway. About 48,000
gallons of leachate per day is currently being collected.
Aside from normal landfill materials, there are chemical industrial wastes and
radiologically contaminated materials deposited in this landfill. The chemical
wastes, that we know of, include about 4,000 tons of residues from the production
of insecticides and herbicides. These pesticide wastes were deposited by
Chevron Chemical Company. Also included in the chemical wastes are waste
materials from ink manufacture and from the manufacture of glue. Among the
chemical wastes that we know of in Westlake Landfill are:
waste ink pigments
esters alcohols
halogenated intermediates
oils wastewater sludges
heavy metals asbestos
oily sludges
insecticides
aromatics
herbidices
Joseph
Fred A
Besides chemical hazardous wastes, in Westlake Landfill, there are radioactive
wastes. During early 1973 Cotter Corporation buried radioactive Barium
Sulfate Slag material and radiologically contaminated building rubble. There
are approximately 9,000 tons of this material which contain about 7,000″tons
of natural Uranium. In October, 1977, an aerial radiological survey was done to
determine the location of the burial of this contaminated material. The report
from this survey indicates that there are two burial sites. One is in the
center of the old quarry area, and the other is on the edge of the floodplain
area which borders adjacent farmland. The U.S Nuclear Regulatory Commission
has contracted Radiation Management Corporation to do extensive on-site
radiological surveys which include groundwater analysis, core sampling, test
boring, and other tests as deemed necessary. The NRC has given DNR verbal
P. Teasdale Governor Division of Environmental Quality
Lafser Director Robert J. Schreiber Jr., P.E. Director
Westlake Landfill continued
Page 2
October 2, 1980
To: Bob Schreiber
permission to utilize the monitoring wells which Radiation Management
Corporation will be digging, in order that DNR may test for the presence of
chemical hazardous wastes.
There is little known about what went into Westlake Landfill prior to State
regulation. Analysis needs to be done to determine: 1) what wastes are
deposited in Westlake Landfill, 2) if any of these pollutants are leaving
the landfill via groundwater, and 3) what threat does Westlake Landfill pose
to drinking water supplies.
cc: Fred Lafser
Ron Kucera
Jim Long
Robert Robinson
Bob Miller
Tom Doan

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1979-12-31 – MDNR – Letter to DOE – Request for report on aerial survey of West Lake Landfill

———…. –.—————–· –
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December 31, 1979
Mr. Earl Harbison
Department of Energy
0Jk Ridge, Tennessee 378JO
Dear Mr. Harbison:
//
‘ ‘
Please find attached my letter of respomc to the c:ty of Brid~etr.n
regarding their resolution relative to the disposJl of radi( .. :tivE
waste materials in the vicinity of the city. Mr. Rick koberts, \’1itl1
the Department of Natural Re:.::>urces, Sol id ‘..laste Mariag~ment Progrc::m,
1s been in telephone corm1unication with you during recent months
requesting that your office provide us \’.’ith the res1:lt-. of the
technical study which was conducted to determine the lJcation ana
levels of radiation er.iitting from the \’1a;te dispo~ec! of at tre
l·lestlake Land4’ill in St. Louis County. This aeriill su,…vey of th·:
Westlake Landfill and other areas in the St. Louis Cou1t; was corducted
at least a year ago. The Department of llJtur·al R~scurces
\’1ould appreciate this information being made availatile in order that:.
we can assess the potential public health effect~.
If there are reasons why the study cannot be rele~sed to the
Department of Natural Resources, I 111ould appreciute te1nc; so acvisei_;.
Sincerely,
James P. Odendahl
Director
Division of Environmental Quality
JPO/RMR/jc
Encl.
JostZph P. Tea~dalcr Gov

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1979-11-08 – Senator Dirck – Letter to MDNR – Missouri’s role in cleaning up radioactive waste at West Lake

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Jli:tl”t:Hs0:-1 CITY
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CA,.ITOL :JUILDINO
JU”ll’llON CITY. MISSOUlll 111101
TILl,.HONI I J 14 I 711.z … 0
November 8. 1979 1014t· •r. •··.
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TIL.IP’H .:JN’. I JI.a .
Mr. James Odendahl, Director
Division of Environmental Quality
P. 0. Box 1368
2010 Missour _ Boulev.L:·d
Jefferson City, Missouri 65101
Dear Mr. Odendahl:
Attached please find a copy of a l~tter and re~~·
lution that I received from Mayor Bill Abram o[
the City of Bridgeton, St. Louis County. Although
I realize the Nuclear Regulatory ~orrunission has
responsibility for disposal of radjoactive waste
materials, I would appreciate your responding to
Mayor Abram and advising with regard to Missouri’s
role, if any, i~ this area.
Thanks for yo~r help.
Sincerely,
(~u/.AJ~
Edwin L. flirck
CLO: ls
Enclosures (2)

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1979-12-28 – MDNR – West Lake Landfill – Letter to City of Bridgeton – Response to Resolution R-79-12

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December 28, 1979
llonorable E. 1-1. (Bill) Abram
MJyor
City of nrid9eton
11955 Natural Bridge Road
Oriugeton, Missouri 6304~
Dear Mayor Al~ram:
S1~nator Edw;r, L. 01rck ha:.. fort.·arded tl1e City of nridg~ton’s Resolution
R-79-12 reliltive to dispo~.Jl of radioacti\’e milterial tc the Depa!”trnent
of ~latural Resources for re~ponse relativE· to Mi~souri’s role in control rr;
tlte disposal of radioactive wilste rnrlterials.
You are probc.bly aware thilt the Federa~ riuclear Regulatory Corm1ission fia’..
tile primary responsibility for controllinu the disposal of radioactive
w~ste materiols. The Sta:c of Missouri is not an agree1.1ent state and
h1s no arrdn~_·ement” with the :luclear Regulatory Comrnis~ion to enforce ‘:.hr!
r~ ~·ithin d.e St.1tc of t1i>souri. At the pres·:?nt tir.ie the Solid
·,J1~te Regulations of the f>cpurtnient of ildtural Resources prohit:it the
accrptance of radioactive ~d~te materials at per~it:ed sanitary lan~fil~ ..
The,.cforl’, the l·lestlake L.111dill in St. Louis County does nut lia·,ie autho
izJt.ion to accept radioac:i·.-c 1·1ast.e rnat.er~als. Tt1e DEpartment of ~at~.ir..i,
;t~~ourccs is interested in 1:hat radioac:t ive 1~aste mat!Jials r.ia1 hdve be1:;
di~.pc:;ec1 of ;.t the Wc~tla’:f’. Landfill iri tt1e past un1 hds been in corn11niC.
l’:.’on .,Jith the Oepartmen~ of Lnergy in 1).lkridge, T·~nn~c;see reciue:;tin~1
t 1tlt the; pr11vide us ~1ith 11i1Jt inf0rr:1a:.ion t~ey i1,1vr: ctitainc:d rel.1t~vc : 1
tw disp0·.3J of the v1aste i1l tl1e .Jec;tL•~’? L.:indfill. ~·r. Earl Harl 1 iscn
1·1ith the (Je~ .. ~·tment of En-~rt:Jy llas assured us he vii 11 ~rovide u~. w1 th d r ·
•)f ~lie inves·.iuation rc;:>0″~ .~s soon clS it is availa111c.
lt l1us Geen ;ndicated triat .’l’ry lo.” lr.-t l rudioacli 11c t1u::.te n.dter·iai w.1·
in·1olved in ·:he disposal H the ~.Jcstlal:f Landfiil, anc there sho•1ld her:·
·jJrl’Jer to th .. citizens of i;r·id·.1et•Jr .. 111· .. 1,!vcr, t~w :>c~.irtrnent of rla 0.:.Jr2l
~e··,uurces via:rts to 1·evicH :1l Ll.!cr1nii:ai J.Jli: fro:? t:1t r1l:parl1;1e11t of ::1r.
in·1·~stigaticr1 ar:d stuJy Li:·’.:· t: 1.akir.·J .11 -1 rf’c01m1~!rl(~.1t .inc; as to 1·1lia·. 1 .. ·
>11·1uld be tai.en.
Joseph P. Teasdale Gov;;-rnor
furd A. Lafser Director
Divi’.ii0n ot Enviror~m . , , !al (luclPy.
James P. Odendonl u1rictor

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

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

Post

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

i1 f^-
MEMORANDUM
* ^*wt
SEP 2 5 1980
SOLID
Date: September 25, 1980
To: Robert J. Schreiber. through Richard F. Rankin
From: Burt McCuiiough
Subject: Westlake Landfill
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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
40056883
SUPERFUND RECORDS
Joseph P. Teosdale Governor
Fred A. Lafser Director
Division of Environmental Quality
Robert J. Schreiber Jr., P.E. Director
73
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Post

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

On June 23, 1976, telephone contacts were made with Dr. E. Edgerley
and with Mr. Phillip K. Feeney of Ryckman, Edgerley, Tomlinson &
Associates, an environmental engineering firm that provided consultant
services to Cotter Corporation on health physics and site decontamination.
Dr. Edgerley stated that while he had visited the Cotter Corporation
Latty Avenue site when the residues were being dryed and shipped to
Canon City, Colorado, he had no personal knowledge concerning ·the
disposal of the material remaining onsite after these operations were
discontinued.
Mr. Feeney stated that he was aware that the topsoil was stripped from
the Latty Avenue site and trucked to a landfill but he did not know which
one. He indicated that arrangements regarding the disposal operations
were made directly between Cotter Corporation’and B&K Construction
Company. Feeney stated that he visited the site to perform a termination
survey after being informed that the disposal operations were completed.
During the first survey he made he found one small spot above 0.6 mR/hr.
He instructed B&K to remove some dirt from this area which he indicated
would be a truckload or less. Subsequently, he returned to the site and
found less than 0.1 mR/hr. By letter dated May, 1974, the results of
Feeney’s survey were furnished to Cotter Corporation. A copy of this
letter with ~ts attachments appears as Exhibit D in this report.
Visit to B&K Construction Company, St. Ann, .Missouri
On June 24, 1976, Mr. Robert S. Davis, Vice President, B&K Construction
Company, was interviewed.· Davis stated that the amount
of material shown on the invoices submitted to Cotter Corporation was
disposed of by trucking to the West Lake Landfill during the period
July 16 to October 9, 1973 with the exception of 5,000 tons. He indicated
that this 5,000 tons represented topsoil stockpiled in one corner of
the Latty Avenue site. He had removed it and then returned it to the
site after disposal operations were completed. This topsoil along with
other topsoil was used to dress the site. He felt that he should be
paid for handling the stockpiled topsoil and that the 5,000 tons was
included in the amounts on the invoices sent to Cotter Corporation.
Davis stated that while there was no charge for dumping the material
at West Lake, he had arranged to have the individual operating the scales
there to record the weights of each truck on sheets of paper. He indicated
he was required by Cotter Corporation to submit these weight sheets with
the invoices. Davis provided copies of the weight sheets which bear
the heading “B&K Dirt Hauling” and the date. The following information is
– 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 –
n
WLLFOIA4312- 001 – 0018548
..
The results of the August 11, 1976 surveys of the Latty Avenue site and
the West Lake Landfill site with a narrative and reference material are
attached to this report as Attachment A.
Results of the analyses of the environmental samples taken on August 11,
1976 from the Latty Avenue site and West Lake Landfill site are attached to
this report as Attachment B.
Measurements performed at the West Lake Landfill and analyses of samples
from the area have been reviewed. The following hazard analysis is based
on the measurements and analyses and on information derived from personnel
of the former licensee.
Direct Radiation – West Lake Landfill
Beta-gamma measurements made at three feet from the surface indicate two
general areas where readings above background were noted. These measurements
indicated 0.06 mrad/hr maximum. The measurements at contact
indicated 0.8 mrad/hr maximum, and about 0.1 mrad/hr average. Thus, for
continuous exposure the maximum gonadal or whole body dose would be:
0.06 mrad/hr X 8.76 x 103 hrs
500 millirems/year. year 500 millirads/year or approximately
However, the area has been closed for dumping by Missouri DNR and is
essentially unoccupied.
Calculated Atmospheric Concentrations of Rn-222 at West Lake Landfill
West Lake Landfill area sample analytical results do not indicate the
presence of significant natural uranium activity. These surface samples,
however, would not be expected to be representative of material which
is reportedly covered by overburden with a thickness of approximately
one meter.
According to information provided by the licensee, the covered material
consists of approximately 7 tons of natural uranium in about 8,700 tons
of barium sulfate and about 39,000 tons of soil. Thus, an approximate
natural uranium weight percentage of the mixture woul~ 7be 0.015 percent.
With a natural uranium specific activity of 6.77 x 10 Ci/g, th~ 10 specific activitl4of the mixture would be approximately 1.0 x 10
Ci/g or 1.0 x 10 uCi/g. Analysis of two surface samples from the Latty
Avenue site (source of the covered material) ind!~ated natural
uranium concentrations of approximately 1.0 x 10 uCi/g, which supports
this estimate of average mixture concentration. !~e Ra-226 analysis
showed an average concentration of about 1.0 x 10 uCi/g for the two
samples.
– 10 –
n WLLFOIA4312- 001 – 0018549
Calculations have been performed to estimate radon-222 emanation from
the ground,_1ue to buried material with an average Ra-226 concentration
of 1.0 x 10 uCi/g below a depth of 100 em. These calculations indicate
a total release of approximately 0.1 uCi/sec of radon-222 from the
ground due to the covered tailings mixture. It should be noted that
the assumed depth of burial yields a reduction of about a factor of
three below what emanations would exist, assuming no cover.
Additional calculations were performed using the ‘·’virtual point source”
method for determining average air concentration of radon-222 above the
covered material. The area was estimated to be approximately square,
lith a dimension of forty meters. This calculation yielded an approximate
0 atmose2eric d!spersion coefficient in the center of the area of
f.7 x 10 sec/m •
Applying this coefficient to the release rate of 0.1 uCi/sec_~ields jn
average increase in background air concentration of 1.7 x 10 uCi/m
directly over the covered tailings, which is about one-half of the
10 CFR 20 unrestricted area concentration limits. This Rn-222 contribution
in air, due to the buried materials, would be indistinguishable
from backcround within a few hundred meters from the landfill. Based
on the conservatism of assumptions, this atmospheric concentration of
Rn-222 is considered an upper limit. Calculations are appended to this
report as Attachment c.
Other Pathwa;ts
Pathways other than direct exposure and inhalation of radon-222 and progeny
do not appear to be significant. No likely means of an ingestion
pathway were identified, and inhalation due to fumigative dusting can
be discounted since the material is covered and not subject to b~coming
airborne. An evaluation of the potential for groundwater contamination
could not be made in the absence of information concerning the hydrogeologic
character of the local area. Three shallow (about 20 feet)
wells in the area were all found to be dry at the time the IE:III
inspectors visited the site, precluding collection and analysis of
groundwater samples. As noted above, barium sulfate and u3o8 are known
to be insoluble in water.
Future Development
It is noted that the radium 226 concentration of materials
presumed buried at the West Lake Landfill approximates that found
in tailings materials used for leveling, aggregate and backfill
under or around the foundations of dwellings in certain western
Colorado communities. Some of these Colorado dwellings experience
indoor radon 222 concentrations capable of yielding exposures
approaching those implied in the occupational limits of 10 CFR 20.
Differences in the physical and chemical natures of the West Lake
Landfill and the western Colorado tailings, however, suggest a
lower radon release fraction for materials of the type buried
at the land fill. Recognizing the potential for radon buildup in
– 11 –
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..;. —-·-.. ~
Conclusion
Seven tons of. uranium could be disposed of by burial in accordance with·
10 CFR 20.304 in an area significantly smaller than that now existing
at the West Lake Landfill. Based on our estimates of maximum potential
exposure conditions by various pathways, it is concluded that the
material now present at the West Lake Landfill does not represent a
radiological hazard by any pathway yet identified. Based on studies of
the use of uranium tailings for backfill and leveling under and around
residence foundations in Colorado, it is estimated that increased indoor
radon and radon progeny concentrations could be experienced in structures
built directly in or on the disposed tailings. An environmental
impact analysis is required for an accurate estimate of the hazard
potential for this pathway.
Attachments:
l •. Attachments A, B, C and D
2. Exhibits A-E
3. References 1-4
– 12 –
r1
WLLFOIA4312- 001 – 0018551
·.
ATTACHMENT A
During a survey performed by this office on August 11, 1976, to
determine the effectiveness of Cotter Corporation’s decommissioning
of their Hazelwood, Missouri (Latty Avenue) site, a difference in
the radiation readings supplied by Cotter and those found by this
office was noted.
On May 10, 1974, Cotter reported exposure rates which ranged from
0.01 to 0.4 mR/hr measured at three feet above grade (type of instrument
unknown). (Reference 1) These values were the basis for
·termination of the license by the Directorate of Licensing.
(Reference 2) The Region III August 11, 1976 survey, made at the
same distance, yielded readings ranging from 0.3 to 0.8 mrad/hr
beta-gamma. (Reference 3) Additionally, a survey at one centimeter
revealed t~o areas reading 1.2 and 1.8 mrad/hr beta-gamma. The
instrument used by IE:III inspectors in performing these measurements
was an Eberl~ne E-SOOB with an end-window Model HP-190 Hand Probe
(1.4-2 mg/cm ).
The presently acceptable limit for release of ground areas, as implied
in the “Decontamination Guide” (Reference 4) is 0.4 mrad/hr, total,
or 0.2 mrad/hr, average, with a maximum of 1.0 mrad/hr, all of which are to be measured at 1 em with a probe of not more than 7 mg/cm 2
of total adsorber. Thus, the NRC Region III survey of August 11, 1976 ·
showed radiation levels at the Latty Avenue site exceeding the acceptable
release limits, while the survey performed by Cotter Corporation
showed levels within the guidelines. Both surveys indicate a low, nonhazardous
radiation level. The difference in results might be
artributable to differences in instruments and procedures used. The
August 11, 1976 surveys were the first independent examination by NRC
of radiation levels at the Latty Avenue site.
..
n WLLFOIA4312- 001 – 0018552
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Sample No.
L-1
·L-2
L-3
L-4
W-1
W-2
.. Note: 1)
2)
3)
4)
5)
ATTACHMENT B
ENVIRONMENTAL SAMPLE
Analytical Results by HSL
Results (uCi/g)
Sample Description
Soil
Soil
Vegetation
Wet Sediment From
Cold Water Creek
Soil
Soil

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

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

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

…. – ··–·-
… ·t .,.,
f ( I f INVOICE (
JV}G 21 ·l· .c.. :I :~,:1t
.4000 7·5666 ( t •••• (· t
c • • t c ..
B. &. K. :Con ~.: -~- G · .. u.. any, Inc.
! f: . .::;!:ff.Y.f..: i~J ~~ ~H B & K”
I {?§jj_..,;;
f ~-! ,.~ .r: … , ·i,..,v f ‘ … .,-. • .,. …… ·’~’— ·—-
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
THIS INVOICZ DUE Al~u PAYABLS WITHIN TEN (10) days.
• nuns
• SVlOIVISION$
• fACTO~Y HOOU
• I’AII

Post

1988-10-25 – MDNR – West Lake Landfill – Letter to EPA requesting determination of Hazard Ranking Score

_. vfv . < • • » . . . • . ,,;;, • . i. i .• /: tfd JOHNASHCROFT \y(li*Ir>
DuiMcin ol I mironnu-m.il Otulii
UIVIMOM ,,| („…,!,w jnj |J1Klsi,n
FREDERICK A. BRL’NNKR “”X” “”VM-m ,» M.in^-tm-m x-rvuvi)
irix.t,,r STATI: (>i MI>S(>riu nm>i,,n ,,f |.arkv R^…^,,,,.
DEPARTMENT OF NATURAL RESOURCES “” “1N”W”””Jllim
Di\’isioN OF I:NVIRONMI;NTAL gi’Ai.nv
I’.O. Box 176
Jefferson City. MOdSI()2
October 25, 1988
Mr. David Wagoner, Director
Waste Management Division
U.S. EPA Region VII
726 Minnesota Avenue
Kansas City, KS 66101
Dear Mr. Wagoner:
The U.S. Nuclear Regulatory Conmission (NRC) staff recently released
a report (NUREG-1308, June, 1988) on the radioactive wastes at the
Westlake Landfill in St. Louis County, Missouri.
In the report the NRC staff concludes that “(1) measures must be
taken to establish adequate permanent control of the radioactive
waste and to mitigate the potential long term impacts from its
existing storage conditions and (2) the information developed is
inadequate for a determination of several important issues, i.e.,
whether mixed wastes are involved, and whether on-site disposal is
practical technologically, and, if so, under what alternative
methods.” However, the report does not indicate whether the NRC will
take any further action at the site and informal communication with
the NRC staff indicates that NRC does not intend to take further
action.
The suggestion has been made by a number of state and local officials
and citizen’s groups that the U.S. Department of Energy should
undertake action at the site under the Formerly Utilized Sites
Remedial Action Program (FUSRAP). However, a letter from DOE was
received by the Missouri Department of Natural Resources on
October 30, 1987 which states that [‘the DOE has reviewed the
possibility of the Westlake Landfill being designated as a FUSRAP
site and has concluded, based on the criteria used to designate
FUSRAP sites, that the Westlake Landfill is not eligible for
consideration as a FUSRAP site. The radioactive waste was under
Nuclear Regulatory Commission license when it was brought to the
landfill and, consistent with current DOE policy, would not be
disposed of at a DOE site.”
Mr. David Wagoner
October 25, 1988
Page 2
Since no further activity is planned at the site by either the NRC or
the DOE, I request that the U.S. Environmental Protection Agency
(EPA) determine the Hazard Ranking Score (HRS) for this site and, if
appropriate, place the site on the National Priorities List (NPL).
This ranking should be conducted using all currently available
information on the site. Further, I request that EPA initiate the
Superfund process to determine potentially responsible parties and,
if necessary, initiate enforcement action to begin an appropriate
remedial action.
The Missouri Department of Natural Resources believes that the
current uncontrolled condition of the radioactive waste at the
Westlake Landfill is unacceptable and we are interested in expediting
action at this site. Please contact me if you have any questions
regarding MDNR’s position on this matter.
Sincerely,
DIVISION OF ENVIRONMENTAL QUALITY
William C. Ford/Director
WCF/dbc
cc: Mr. Jim Fiore, DOE
Mr. Germain LaRoche, NRC

Post

2016-01-29 – EPA – West Lake Landfill – EPA developing response to independent journal study indicating offsite migration of radon

To:
From:
Sent:
Subject:
Smith, Mark A.[Smith.Marka@epa.gov]
Algoe-Eakin, Amy
Mon 2/1/2016 5:11:38 PM
FW: WL update 1/29
From: Hooper, Charles A.
Sent: Friday, January 29, 2016 1:49PM
To: Jay, Michael
Cc: Doolan, Stephanie
Subject: WL update 1/29
Here are some of the highlights of West Lake activities this week:
-The interim reports by MDNR and MDHSS from their Nov 2-4,2015 sampling from around
West Lake Landfill were posted. Two areas of slightly elevated exposure readings were found in
the general area of the Buffer Zone property but no public health concern was noted.
-Developed and posted draft general talking points on radon and lead-210 on the SharePoint for
the WL team to review. This is the preliminary step with a more technical response to the journal
to be developed later, along with some sampling background sediment.
-Learned of a new community engagement plan from OPA. More details to be provided during
our meeting next week.
-Alyse is considering the addition of a gas assist for the flare as part of the Isolation Barrier (IB)
negotiations.
-Follow-up conference call on risk calculations for the Radioactive Impacted Material (RIM) on
the south side of the proposed IB location.
-A State senator has proposed legislation for a buyout of homes within three miles of the landfill.
-Related to that are two US congressional bills that would transfer West Lake to USACE,
introduced by the Missouri congressional delegation.
WLLFOIA4312- 001 – 0057297
Chuck Hooper, CHP
Radiation Safety Officer
EPA Region 7
11201 Renner Boulevard
Lenexa, Kansas 66219
(913) 551-7271 office
WLLFOIA4312- 001 – 0057298

Post

2009-12-28 – EPA – West Lake Landfill – EPA facing fresh pressure at key St. Louis-area radioactive landfill site

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WLLFOIA4312 – 001 – 0055917
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WLLFOIA4312 – 001 – 0055920
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4
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5
WLLFOIA4312 – 001 – 0055924

Post

2009-11-16 – EPA – West Lake Landfill – Cleanup of nuclear waste in landfill site on hold amid fears of precedent

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Post

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

To: Tapia, Cecilia[Tapia.Cecilia@epa.gov]
Cc:
From:
Field, Jeff[Field.Jeff@epa.gov]; Kiefer, Robyn V NWK[Robyn.V.Kiefer@usace.army.mil]
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.
Sincerely,
Sharon Cotner
—–Original Message—–
From: Tapia, Cecilia [mailto:Tapia.Cecilia@epa.gov]
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
ROD?
Thanks
WLLFOIA4312- 001 – 0058973
Cecilias Microsoft Outlook Signature large font
Classification: UNCLASSIFIED
Caveats: NONE
WLLFOIA4312- 001 – 0058974

Post

2015-03-05 – EPA – West Lake Landfil – Hot Topic – Air Emissions from Burning of Bridgeton Landfill

From: Cacho, Julia
Required Attendees: Brooks, Karl; Field, Jeff; Carey, Curtis; Hague, Mark; Slugantz,
Lynn; Peters, Dana; Jackson, Robert W.; Stoy, Alyse; Vann, Bradley; Cozad, David; Brincks,
Mike; Weber, Rebecca; Smith, Mark A.
Location: R7 -R02.2-P46-8/R7 -RO
Importance: Normal
Subject: Update: West Lake Landfill (call in number: r.-~:-~.-~.-~.-~.-~.-~.-~.-~.-~.-~.-~.-~.J access code: E.~.~-~-~j
Start Date/Time: Thur 3/5/2015 3:00:00 PM
End Date/Time: Thur 3/5/2015 4:00:00 PM
WLLFOIA4312- 001 – 0058257

Post

1988-08-15 – Post-Dispatch – West Lake Landfill – Agency – Landfill Cleanup Needed

MONDAY. AUCVST 15. 1988
Agency: Landfill Cleanup Needed
BuCaratyit at the landfill or should be moved
Radioactive material Illeftlly
dmnped at Ike We*t Lake Landfia In
Brtdcetoa IS yean a«o has contamtnated
aearwy aoH aad groaad water
aad alKMM be deaaed »p. the V3
Nuclear Regalatory CommtMloa
la a i tan week,
Ike aatnry laaad tkat a cttaaap war
of “potcatlal loa(-
Mat tka report
tayt tkat H b aaNkety tkat aayoae
MirccarvN alB^fk»nt radtatloa
frow ttw jlw. ~m — IWf
ral RaBMTcw baa wM tke kwdftfl
POM a beam (treat
Tkc fadctal aajcacy aBM a daaaaa)
caaM c«at fram UTa.aa. to $M aiHn
«n la 1N4 doflan. Newer coal eatt-
Tke report, aaaie af wkte> hag tak-
•a five yean lo coaiavewx atyv more
a)«4y b) aeedad to determine whether
the ITf.Mf cabtc yard* of contamtnated
material coaM be stored lately
The tandfin Hes mirth aeja: of the
Intersection of Interstate* TO and 27*
a«l east of Earth City. It to sarroanded
by restdeatlal pibdtvrtons. a farm
and tndmtrtal development
Federal otflclah< have aatd the Wett Lake material coatd not be itored at Ike earthen banker Owl has VMV pTOpOvBd fOC 82.7 aKTM IwOfth Of Lantbert FteM. Offlctaki have propoaed avendtng |2*t mllltoa to ftore aboat 7M.OM cabk yardsol radloacttvc nvlvrtol from ^H»?wfc*?rc In ttic St Loato area at that dte. The contamtaattoa at Weal Lake, at 1ST* St Cbarte* Rock Road, and the ether tMcs M thb area It left over from araatam proccarins la St Loahi tor aadear weapom In tke IMai and IM*. The artaawr luotamlnanb at Went Lake LandfHI are thorium lM and radtam IM. both of which can ca«se cancer. Content rattem of the radioactive tabctaace* la the soil and uroaad water at the 200-acre landnil exceed lederal cleanup the report say<. The concentration of thorium 2.10 In soil at We*t Ijike mnftex as hHch us I*.IM plcocui1e5 a gram. It averages about 9.000 ptrncvrtf* a rn»m. federal offtrtals hnvr witd The normal concentration of thorium 23A In soil hi St LftuH County rum about 0.2 picomries a Kram. • The concentration of radium 2711 at the landnil hat been found a* high as CM plcocartes a gram and averages aboat M ntcocurtei a gram, officials have said. Normally, • 5 ptconirtes a gram of radium 226 are found In soil In thH area. Because at the way the elements decay, the concentrations of radium 2M and mdoa 222. a gas that Is estremety harmful If Ingested or Inhaled, are expected to Increase ntaefoM over the next 200 years at the landfill. The report says some of the radioactive material on the northwestern edge of tke landfill ha* no protective cover of mil to prevent the spread of contamination. The commMon also sak) that tests showed "some low-level cootamliw tkm of ground water." Indicating that the waste was leaching thrnagh the landfill Further complicating a cleanup. Ike radioactive material may have become miied with chemically hazardous material, the report saw. "Under these condition*, oa-site disposal. If possible, win likely require moving the material to a raretally designed aad contracted 4b>
pnsel cell.” the report says.
Counclrwomaa Peggy J. hleyer of
Ward I hi Rridgelon said Saturday
that city offl«-‘-.K support cleanup of
the landfill
Bat Brtdgetoa offldak. like other
ofndaki In aorta SI. Louts Coaaty.
have urged that Ika. We* Lake malerial
and an the radioactive material
In lati area be consolidated and
moved ovt of tin? poptttotesd cm.
-My nnt reaction to rats report b
•Let« net started.’ • Meyer saM.
The Wett Lake properly wai
bought wtthln the last month by Latdtow
Waste System Inc.. a rrnsh-co»-
kctktn company, fmm the Archdlo-
Lout*. M^vrrsald.
ST LOUIS POST-DISWTCH
West Lake Landfill
In itTJ. aboat I.TM toa§ of radial
active bartam salfate cake from q
nearby radioactive wfjate atte an
Latty Aveaue la Haielwood wrt
dumped IHegalry at Ike Weat Lake

Post

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

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

Post

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

JAN I 9
MEMORANDUM FOR: Stuart A. Treby, Assistant General Counsel
for Rulemaking and Fuel Cycle, OGC
FROM: Richard E. Cunningham, Director
Division of Industrial and
Medical Nuclear Safety, NMSS
SUBJECT: PROCEDURE REGARDING RADIOACTIVE WASTE IN THE
WEST LAKE LANDFILL
This is a request for advice regarding what legal recourse we have to require
a former licensee, the Cotter Corporation, to properly dispose of radioactive
wastes dumped in the West Lake Landfill (Docket No. 40-8801.)
In 1973, some 8700 tons of radioactive leached barium sulfate wastes from
uranium ore processing were nixed with soil and dumped in the West Lake Landfill
on the outskirts of St. Louis, Missouri. This action by a contractor for the
Cotter Corporation was taken without NRC authorization.
We have reviewed NRC contractor reports of field investigations of the
West Lake Landfill, NRC records and information from the Missouri Department
of Natural Resources. Based on this review, we have prepared a Draft Summary
Report which discusses the radiological and environmental circumstances of
the wastes. From this review, we have concluded that remedial action is called
for, but that additional technical information and engineering evaluations are
necessary to determine how it should be accomplished. We also need to determine
who should be responsible for conducting the studies and the remedial action.
Enclosed is a copy of a letter from Region III to the Cotter Corporation, dated
June 11, 1976, transmitting inspection reports that provide a history of the
wastes in the West Lake Landfill and a copy of the Draft Summary Report. If
cdditional Information is necessary for your determination, please contact
L. Rouse or J. Swift of my staff.
Stuart A. Treby 2 2 9 1988
It is important to act promptly on this matter, because the disposition of the
West Lake Landfill wastes has been raised as an issue with regard to negotiations
over which State will host a compact’s low level waste burial site.
Original Signed By:
Richard E. Cunningham, Director
Division of Industrial and
Medical Nuclear Safety, NMSS
Enclosure:
1. Draft Summary Report “Uranium Ore
Processing Wastes in the West Lake
Landfill,” draft of January 28, 1988
2. Ltr of 6/11/76 to Cotter Corp.,
fm JMAllan, RIII with enclosed
inspection reports on Cotter Corporation’s
Latty Avenue site/dumping in the West Lake
Landfill.
DISTRIBUTION NMSS 87082& w/encls
Docket No. 40-8801 IMSB R/F NMSS R/F
NMSS Office R/F IMNS Central Files CJenkins
CEstep LCRouse JJSwift
VLTharpe GLaRoche .
OFC: TWFTn/ IMSEfa/T DD:IMNS: DIE: IMNS:
— — ^,-y^z^
LRo’use: : GLSjoblom: : “-RtCUfTntngham:
DATE; 1/^/88; : lM/88: M /88;
‘ l OnFFFrIiCr Ii AALI RRFErCnO&RDn CrOnPpY

Post

2015-05-06 – EPA – Talking Points for Meeting with Senator McCaskill’s Office Regarding West Lake Landfill

Talking Points for Meeting with Senator McCaskill’s Office Regarding West Lake Landfill
May 6, 2015 Meeting, Washington DC- DRAFT Vl 4/30/15
Recent and On-Going Activities at the West Lake Landfill
• PRPs have agreed to define extent of RIM at the northern boundary of the North Quarry
under an EPA workplan and EPA oversight in the field. This will aid in both the decision
on an isolation barrier as well as the decision on the final remedy at the site.
• PRPs have agreed to conduct additional investigation in Areas 1 and 2 to refine the
boundaries of the location and extent of RIM.
• EPA has also recently directed the PRPs to submit revised work plans related to the
partial excavation alternative analysis. This is a key step in moving forward towards the
final remedy evaluation.
• EPA is planning pyrolysis testing of soil samples containing RIM. This analysis will expose
soil samples to temperatures similar to temperatures associated with those of the SSE in
the South Quarry.
• We are continuing to work closely with MDNR to monitor the SSE at the Bridgeton
Landfill and evaluate any potential impacts should the SSE come into contact with RIM.
• PRPs have been directed to submit to MDNR all H2S and S021andfill gas related data;
calculate potential estimated S02 emissions from the on-site flares and submit a permit
application for the flares that includes sulfur control technologies.
• EPA and MDNR are working together on the S02 matter. EPA supports MDNR/AGO in
enforcing their deadlines set for the PRPs. If needed, EPA has option of issuing Clean Air
Act 114 request for information and/or order for testing.
• EPA and MDNR are exploring options for mobile H2S and S02 monitoring within the
community, which could also help inform any additional monitoring in the community.
Potential timeframes- June/July for mobile monitoring and fall for siting stationary air
monitors.
EPA Response to Just Moms STL Request for Relocation:
• The Bridgeton Landfill (former active sanitary landfill) is included in the 2008 Operable
Unit 2 Record of Decision (OU-2 ROD). EPA deferred implementation of an EPA
remedial action for the Bridgeton Landfill to the State of Missouri pursuant to the
requirements of the state’s existing closure and post-closure permit.
• EPA continues to have CERCLA response authority to ensure protectiveness of human
health and the environment for releases of hazardous substances from the Bridgeton
Landfill.
• EPA’s relocation authority under the National Contingency Plan includes: “[t]emporary
WLLFOIA4312- 001 – 0058370
Talking Points for Meeting with Senator McCaskill’s Office Regarding West Lake Landfill
May 6, 2015 Meeting, Washington DC- DRAFT Vl 4/30/15
or permanent relocation of residents, businesses, and community facilities may be
provided where it is determined necessary to protect human health and the
environment” (Title 40 of the Code of Federal Regulations (40 C.F.R.) section 300, App.
D(g)).
• Based on the scientific data we have at this time, EPA has determined that
circumstances at the West Lake Landfill Superfund Site do not currently warrant the use
of permanent relocation pursuant to CERCLA authority.
• Example of Herculaneum-Doe Run.
o Lead emissions and lead contaminated soils were suspected to be the cause of
elevated blood lead levels in the surrounding community.
o EPA performed a fund-lead removal action at Herculaneum, as a part of that
action EPA provided a temporary, voluntary relocation during the interior cleanup
of homes for a limited number of residents with health concerns and/or young
children.
o In addition, Doe Run agreed to implement limited voluntary buyout for residents
who lived closest to the smelter under an April 2002 agreement between
Missouri AGO, MDNR and Doe Run (about 145 out of 173 homeowners
accepted a buyout offer).
o Doe Run was a NAAQS non-attainment area for lead at the time of the buyouts and later
for S02. Decisions to offer relocation were not based solely on NAAQS issues with
neither lead nor S02, but on the cumulative health effects on the population and unique
characteristics of lead (soil/air re-entrainment, blood levels, etc.).
o Note that S02 is much more transient and very unlikely that relocation decision would
be based solely on exceedances of S02 (or any other) NAAQS in the Bridgeton area. We
have several areas in R7 (including St. Louis- Ozone, PM) that are exceeding the NAAQS
for one pollutant or another.
WLLFOIA4312- 001 – 0058371

Post

2015-01-04 – EPA – West Lake Landfill – OU1 Removal Action (Isolation Barrier)- EPA Region VII Monthly Report

West Lake Landfill SF Site OUl Removal Action (Isolation Barrier)- EPA Region VII Monthly Report
Bill No.: I 27076647 I lAG No.: DW96958582 I P2# : 444809 I lAG Exp. Date: I 30-Dec-2016
Reporting Period: I From:
1 Dec2015
I To:
4Jan 2015
I EPARPM:
BradVann
I USACEPM:
Robyn Kiefer
Work Performed
Narrative
Meetings
Key Milestones
Projected Work
Narrative
Meetings
Key Milestones
Forlhroming
Project Management: Completed monthly status report and budget tracking. lA
processing/funding acceptance. PDT Coordination.
Coordination for Kansas City District Engineer’s involvement in EPA IB Announcement Press
Event including preparation of potential Q&A
Partici nal discussions lB.
12/1/15 -Kiefer, Specking participate in call with EPA to discuss IB options
12/2/15 -Sexton call with EPA R7 RA (Hague) RE: West Lake IB announcement
12/8/15 -Kiefer, Speckin, Leibbert participate in pre-decisional discussion call with
EPA/MDNR/ORD
12/9/15 -Young, Leibbert participate in EPA R7 RA briefing prep call
12/10/15 -Young, Leibbert participate in EPA R7 RA briefing meeting
12/18/15- Sexton, Ostrander, Young, Leibbert, Kiefer- NWK District Engineer briefing on
West Lake announcement
12/31/15 -EPA makes announcement on IB decision
Review RP’s Comprehensive Phase 1 Report
Review and coordinate response with St. Louis District & EPA on Pb210 article
Assist EPA with core testing effort as requested
Assist in aration for Feb 8 CAG
Attend February 8 CAG meeting.
Complete review of IB installation work plans and designs when they are submitted
Perform preconstruction observation effort.
Issues/Challenges/Risks
—————————————————————————-~
Risk: Delay of decision on IB path forward due to need for additional characterization
reduces alternatives and increases risk of rushed design and construction effort, should a
heating event be identified in North Quarry.
Challenge: Advanced notice of dates when work plans/designs are expected to be submitted
by RP is necessary to ensure appropriate PDT resources are available to perform document
reviews in a timely manner. Advance notice of what USACE support (meetings, briefs,
reports) is required is key to ensuring quality of and ability to support.
Challenge: $80K in additional funding received from EPA. Execution of activities not
included in original budget continues. With additional $80K, projected shortfall (depending
future Technical Assistance tasks roximatel $50K.
1 OF 2
K\MISSIONPROJECTS\H1WIINEST lAKE lANDFILL \PROJECT MANAGEMENT\5-EPA MONTHLY REPORTS
WLLFOIA4312- 001 – 0058924
West Lake Landfill SF Site OUl Removal Action (Isolation Barrier)- EPA Region VII Monthly Report
Bill No.: I 27076647 I lAG No.: DW96958582 I P2# : 444809 I lAG Exp. Date: I 30-Dec-2016
Reporting Period: I From:
1 Dec2015
I To:
4Jan 2015
I EPARPM:
BradVann
I USACEPM:
Robyn Kiefer
lAG Summary
USACE Contract Total Amend Total lAG Date
Reimbursable Direct Fund Cite
320,000 – 320,000 320,000 15-Apr-2014
80,000 – 80,000 400,000 8-Dec-2015
Expenditures
USACE
Funded Current Bill Previous Remaining EAC Notes
Billed Funding
400,000 9,543.40 185,061.08 205,395.52 320,000 See Page 1 -Funding Challenge
Note: This is an in-house action, therefore no contractor expenditures
Scope of Work Summary
TECHNICAL ASSISTANCE, WORK PLAN/DESIGN REVIEW, CONSTRUCTION OBSERVATION SUPPORT, AND COMMUNITY RELATIONS
SUPPORT TO EPA IN THEIR OVERSIGHT OF RESPOSIBLE PARTIES’ DESIGN AND CONSTRUCTION OFAN ISOLATION BARRIER AT
WESTLAKE LANDFILLOU-1, AREA 1, BRIDGETON, MO.
Project Development Team
Name
Robyn Kiefer
Paul Speckin
Jough Donakowski
Pat Conroy
Mary Delaet
Margie Benningfield
Dave Mueller
Bradley Vann
Electronic Deliverable
Robyn Kiefer
Project Manager
816-389-3615
Org Phone
CENWK-PM-M 816-389-3615
CENWK-ED-EG 816-389-3592
CENWK-ED-ES 816-389-3993
CEMVS-EC-GT 314-331-8430
CENWK-ED-DM 816-389-3226
CEMVS-EC-CA 314-331-8040
CEMVS-EC-CF 314-331-8040
EPAR7RPM 913-551-7611
8 January 2016
Date
20F 2
K\MISSIONPROJECTS\H1WIINEST lAKE lANDFILL \PROJECT MANAGEMENT\5-EPA MONTHLY REPORTS
WLLFOIA4312- 001 – 0058925

Post

2015-10-09 – EPA – West Lake Landfill – Heat Extraction Barrier Pilot Study Data Needs

Heat Extraction Barrier Pilot Study Data Needs –Update
Subject: Heat Extraction Pilot Study Updated Data Needs to Adequately Evaluate Potential
Effectiveness of Heat Extraction Barrier, West Lake Landfill
Date: October 9, 2105
Purpose:
One of the alternatives evaluated in the October 2014 Isolation Barrier Alternatives Analysis
report submitted by Bridgeton Landfill LLC is a heat extraction barrier. However, the
Alternatives Analysis report lacked detailed information necessary for USACE to make an
independent technical evaluation of the potential effectiveness of such a system. Since the
October report was submitted, Bridgeton Landfill LLC proposed to expand on the current test
well (GIW-4) and perform a pilot study to obtain information to demonstrate the effectiveness of
this proposed alternative and to obtain data necessary for design of the system. It is USACE’s
understanding that this expansion pilot study was approved by the Missouri Department of
Natural Resources (MDNR) and implemented.
In December 2014, USACE submitted to EPA the information listed below. This list is
information USACE will need regarding the heat extraction study at GIW -4 and the pilot study
expansion system that consisted of retrofitting 6 additional GIW wells with recirculation coolant
tubes, to assess whether adequate information is being collected to design an effective heat
extraction system.
It is USACE’ s understanding that the pilot study data that was submitted to the Missouri
Department of Natural Resources (MDNR) was posted on their website. USACE reviewed the
information posted on the MDNR web site and supplemented the list below with what
information was identified from that web page. The supplemental information is included below
in brackets with text bolded. If there is no bracketed/balded information, we could not locate the
information.
• Schematic of the modified GIW -4 used in the preliminary heat extraction study including
depth and construction of the well and all pipe sizes where fluid is flowing [MDNR website
has a submittal from Republic that shows a schematic of the cooling loop proposed for
the expanded pilot. As-built information was not provided]
• Details of the cooling equipment and/or coolant being used in the pilot study.
• The preliminary data collected from the heat extraction study at GIW -4 including inflow and
outflow water temperatures, flow rate, and the temperature within the casing measured at
multiple depths.
• Calculations to determine the 25kW extraction rate.
1
WLLFOIA4312- 001 – 0059515
• Location of the 6 additional GIW wells to be retrofitted with recirculation coolant tubes
including depth and construction of the wells and all pipe sizes where fluid will flow.
[MDNR website has a Republic submittal requesting expansion of the pilot study and
includes a plan view of proposed GIW wells and locations of proposed new temperature
probes.]
• An explanation ofhow the modified GIW wells are representative of the proposed driven
heat extraction wells and whether or not a pilot study of driven wells of the material proposed
for the full scale system will be tested prior to design and installation of the system.
• Plans of the proposed closed loop header system used to convey cooling water to the
mechanical cooler.
• Location of current Temperature Monitoring Probes and depths and proposed locations and
depths of temperature measurements when the pilot study is expanded.
• Proposed study procedures including assumptions used.
• Proposed calculations to determine thermal conductivity and heat storage properties of the
landfill waste. In addition, how is obtaining thermal conductivity and heat storage properties
of the South/North Bridgeton landfill waste representative of these properties in the proposed
location of the heat extraction system in the West Lake Landfill waste?
• Results of the assessment ofheat front progress to the north and the rate of energy flux to the
north.
• Calculations used to predict the amount of heat that could be extracted under steady state
conditions and the results of those calculations.
• A plan view of the proposed Temperature Monitoring Points as well as a cross section
showing depth intervals of temperature readings. Attachment C indicates it is envisioned as
one array per 120 feet would be sufficient. Is this 120 ft spacing parallel with the proposed
barrier? [[MDNR website has a Republic submittal requesting expansion of the pilot
study and includes a plan view of proposed GIW wells and locations of proposed new
temperature probes.]
• It appears the settling front associated with the SSE would render the heat exchange system
non-functional if the system fell within the influence of settlement (similar to the need to set
back Option 3 IB wall). Therefore, it appears the heat exchange system would need to halt
the SSE and settling front some distance south of the barrier to prevent this failure from
occurring. What distance is this and what temperature needs to be attained some distance
from the barrier to prevent this from happening?
On October 8, EPA notified US ACE that Republic Services had provided them with more details
of the cooling system. Once that information is provided, US ACE will review that information
and provide further updates, as required, on what additional information is necessary to evaluate
the cooling loop pilot with the potential of utilizing it as a thermal barrier option for the isolation
barrier.
2
WLLFOIA4312- 001 – 0059516
If you have any questions, please contact me at 816-389-3615.
V.1271182852
Robyn Kiefer
Project Manager
3
ou=DoD, ou=A

Post

2016-02-18 – EPA – AAA Trailer Services Investigation

To: pau lrosasco@emsidenver.com[pau I rosasco@emsidenver.com]
Cc: Vann, Bradley[Vann.Bradley@epa.gov]; Juett, Lynn[Juett.Lynn@epa.gov]; Barker,
Justin[barker.justin@epa.gov]; Gieseke, Andrew[Gieseke.Andrew@epa.gov]
From: Mahler, Tom
Sent: Thur 2/18/2016 9:25:17 PM
Subject: AAA Trailer Investigation
Hey Paul,
I just wanted to send you a summary of what we just discussed. MDNR and I met with John
O’Brien from AAA Trailer Services today. While there, MDNR provided John a summary table
of the analytical data from their November 2015 vicinity sampling event. I then explained that
EPA had an interest in further investigation occurring on the uncovered soil areas of AAA
Trailer services between their gravel parking lot and the West Lake Landfill Fence. I told him
that this investigation would involve conducting telemeterized gamma scanning and
confirmation surface soil sampling. I told him that the West Lake Responsible Parties’
Representative would be contacting him soon to obtain permission to have access to the property
to perform this investigation. I also mentioned you would likely send a form that would need to
be signed for this access. I told John he would be contacted at a minimum by the end of next
work week (February 26th)but likely sooner. He is ready and waiting to be contacted.
John also mentioned that he would prefer if possible for the investigation to occur on the
weekend when there would be less impacts to their day to day business. John said that he could
provide access to whatever parts of the property need investigation over the weekend.
Let me know if there are any questions,
Tom Mahler
On-Scene Coordinator
US EPA Region 7
816-604-0546
WLLFOIA4312 – 001 – 0015853

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