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.... View Document

Post

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

MEMORANDUM FOR:
THRU:
FROM:
SUBJECT:
JUN 1 6 1978
Chairman Hendrie
Cofonlssloner
Commissioner Kennedy
Coranissioner Bradford
JSlpwd) Lee V. Gossi*
iv
Distribution:
FCPF
NMSS
ixOocket 40-8035
LVGossick
CVSmith,Jr.
SMeyers
RECunningham
JBMartin
LCRouse
EDO r/f
SECY
PE
GC
Volgenau
Shapar
Lee V. Gossick, Executive Director
Clifford V. Smith. Jr., Director
Office of Nuclear Material Safety and Safeguards
REMOVAL OF CONTAMINATED SOIL FROM HAZELWOOD TO WELDON
SPRING, MISSOURI (REF: SECY -78-1 69)
The staff has been 1n contact with the DOE staff at Geraantown,
Maryland,-who has the responsibility for answering your letter to
Mr. O’Leary dated April 24, 1978. In this letter, we reconcended
that the contaminated soil be moved to the Wei don Spring raffinate
pit area in orcier that the property on Latty Avenue can be
decontaminated and released for unrestricted use. The staff’s conversations
with the DOE staff indicate that DOE is contemplating a
neoative response to our suggested use of Heldon Spring and 1s
preparing a memorandum suggesting that the material be consoldated
on site until a permanent low»level waste burial ground is picked,
which could be years from now.
In the discussion of remedial action alternatives, which was enclosed
in your April 24 letter to Mr. O’Leary, the staff rejected on-s1te
storage because the contaminated material would not be removed to an
isolated area, the material would have to be moved at a later date
(this would mean moving the material twice 1n a densely populated area),
and finally the site could not be released for unrestricted use.
Nothing has happened since that letter to change the staff’s position
that movement of the material to the Wei don Spring pit area 1s the
best solution because the site is remote, it is controlled to provide
restricted access, it is owned by the Federal Government, and last but
far from least, it is already contaminated, and the residues from Latty
Avenue would be only a rainiscule increase in the volume of contaminated
soil and rubble presently existing at Weldon Spring.
OFFICE>-
SURNAME>-
DATE>-
•-— ‘ ”
ISTRC FORM 318 (9-76) NRCM 0240 T^ 111 a. GOVERNMENT PRINTING OFFICEl 1976 — 628-824
If DOE insists on their Indicated course of action, 1t could significantly
delay the cleanup of the site because of the complex negotiations
required with the former licensee, Cotter Corporation. The Cotter
Corporation has Indicated that they might be willing to pay for the
movement of the material to a nearby site, but they would resist having
to move it twice or move it a long distance. We view our proposed
solution as the raost reasonable of the available alternatives which
is both technically sound and would also release Mr. Jarboe of a
predicament that was not of his making and 1s currently costing Ma
an estimated $60,OOC/year in cash and an Indeterminate amount 1n lost
business because of the delay in building his chemical plant.
I therefore recorwend that Mr. O’Leary be contacted by phone to
reitterate the need to solve this problem as rapidly as possible
and that disposal to a site other than Wei don Spring would only
cause additional delays.
Clifford V. Smith, Jr., Director
Office of Muclear Material
Safety and Safeguards
6/15/78
. FCPF
WTCrow SEE
6/ /78 ATTACHED FOR
PftWr
OFFICERSURNAME
>-
DATE^-
FCPF
LCRouse
67 778
FCSL
JBMartin
67 778
CVSmith,Jr. LVGossick
6/7F/78
NEC FORM 318 (9-76) NRCM 0240 “£? Ul 3. GOVERNMENT PRINTINO OFFICE! 1S78 –
\
,6/15/78
If DOE 1nst«ts on their indicated course of action. 1t could significantly
delay the cleanup of the site because of the complex negotiations
required with\he former licensee, Cotter Corporation, The Cotter
Corporation has\1nd1cated that they might be willing to pay for the
movement of the Arterial to a nearby site, but they would resist having
to move 1t twice 6r move 1t a long distance. Since our legal hold on
Cotter Corporation Ms tenuous, the litigation posslblltles could keep
a staff of lawyers ttasy for years and still not get Mr. Jartoe out of
a predicament that wa\not of his making and Is currently costing Mm
an estimated $60,000/year 1n cash and an Indeterminate amount 1n lost
business because of the\elay 1n building his chemical plant.
I therefore recossnend thavtlr. O’Leary be contacted by phone to
reitterate the need to solve\th1s problem as rapidly as possible
and that disposal to a site other than k’eldon Spring would only
cause additional delays. \
\
S\
Cl\fford V. Smith, Jr., Director
Office of Wuclear Material
SaV>ety and Safeguards
FCPF
WTCrow^-
6//’>/78
OFFICERSURNAME
^~
DATE^-
FCPJ?/^
LCRousk < 6//4/7S K3L ItyjKjtfa -u....:.. FC RECunningham 6/ /78 . FC SMeyers 67 778 NMSS CVSmith,Jr. 67 778 EDO LVGossick 67 778 NRC FORM 318 (9-76) NRCM 0240 Ul 8. GOVERNMENT PSilNTINO OF.FICEi 1976-

Post

1948-11-01 – AEC – SLAPS – Uranium contamination at Airport Storage Area, St Louis MO

. ··- .. …,- -~ : .’ ·~~. . ,,_ … ‘ t~t:r”·;..;._- -:·L\-l·j•’; -~~:.-.1.-..~ -, 1′ ·:~\ L””
YTOn•IUM CONTAMINALOTUI~~ ATM IASSIROPUORRI T S’l’ORAGE AREA VL\1\ll sr. •
BY
PAv.T~T.Yo B• KLEVIN
·~~;/ a~C; #~ ~~wJ.(__,
T/,r C’-1””” a/ ~0., ~-/
s Atomic Energy ComOnfifsisc1eon u. • I k: Operations
New or 1 Di vi;:i on
November 1 • 1948
Medica
. ,; _-_·-·c(\_.M,·EfJJ.£NfiAt.,.- ~-~~ _ V.tiY
I
M?TRACT
A study of pollution o£ Cold ‘?later Creek and content of
uranium that may be .found in the earth at the Airport .
Storage Area, st. Louis, Uissouri revealed the followinga
1. Creek water samples were well within the limits
of tole ranee.
2. M.ld samples adjacent to the area ranged in value ·
from nil to 190 times that of normal uranium
content in soil.
H~rever, no final conclusion should be drawn from these
samples.
Ad~itional samples both under normal and adverse weather
conditions need to be taken so that the evaluation o!
hazards presented by erosion and drainage both into the
Creek and adjacent area can be more soundly determined.
‘~ •
Egrpose of Raoo~
During the period z~~rch 23 to March 28, 1948 mud and l’later samples were
taken by Paul B. Klavin in the a raas adjacent to t.lJ.e air:9ort storage area,
Robertson, !o:;issouri. This sampling survey nas planned in order to study
(1} the pollution of Cold ~1ater Creek by materials stored or dun?ed at the
ai rport a rea, and (2) the content of uranium that might have soaked into the
soil.
~thod of _s.t u9z
Seventeen water samples werG collected in 500 cc bottles fr~ the various
drainage ditches and streams alongside and adjacent to the storage area. In
addition, samples were collected from the main stream, cold 7’fater Creek.
Samples of water ware obtained from various hiehway bridges frO!ll its oriein
to its mouth.
Fifty mud samples ”are tal(en in 250 cc bottles at both surface and subsurface
levels 01•-.3″ and .3″ to 7″ raspectively; the latter procu.Nd to indicate
pene·tr ation. Using a two inch di.a.metar pi-pe to obtain a 211 x 3″ cylinder
of mud, the sub~urface and surface mud was sampled throughout tht3 area west
of the property, where the most noticeable drainage from. the storage area
occurs. Thera lVere 20 sampling stations along a north-eouth line follotdng the
wast fence appro:x:i.:nately 25 – 30 feet apart. ‘Ihe remaining staticns were wast
of the fenced area along the drainage ditches and a9pr~ll~tely 100 feet apart.
In addition to these samples four control mud samples were taken at distances
of one and five miles from the area.
Soil and liquid samples were· analyzed by the University of Ro<'~he ster for uranium content. A soil analysis result of o.o signifies no uranitun detect ed. If present, the uranium concentration is less than 0.1 micrograms l;.ranium per gram of soil. The sensitivity of the water analysis is 0.0004 micrograms uranium per cc of water. ~scriotion of TeiTain aqjoining...MQ...E!:OJ29rlY at J:!obertson..a J:j. ss~t1 Just prior to the period of mud and water sampling t here had boen gena r-a.l and frequent rains causi ng sluage and residue to be washed onto the adjoining property wast of the area. The area nearest tha west fence was swampy and boggy with many small drainage ditches emanating .from the area itself. In the central portion of the adjoini..l'lg area there is a swampy stretch running northsouth for 250 feet and east"""'f9st f'or 125 feat. 'l'liElnty to thirty feet south of asphalt cover ed Brawn Road which borders the area on the nortn., there was a pool of l'fater 50 feet in length. Due wast of t his pool thora was a.nother swampy stretch 125 feet in length originating or terminating at the swampy section desc1~bed above. All of the ground west of the Sl'Bmp area leading to Cold Vlater C:reek was firm terr ain. Two IDAi."l ditchew originati.ng near the fence area were avident1 one 25 feet directly south of and parallel to Brown Road and the other, a larger one originates in ~~a residue area and runs due west for 500 fest into the creek. -1- . As previously m3ntioned, the rainy weather conditions prior to the' sa:npling period were unusually severe and caused the appearance t)f many ephe;aeral ditches in the area. Cold ilater Creek was swollen and turbulent along its entire course to the Missouri River. Discussion The results of the mud analysis showed conclusively that s01no3 residue from the area had been washed "estward towards the creek. It should b1~ recognized that the weather conditions at the time the samples W9re taken af~ects the amounts of uranium obtained par sample. 1.he uranium tolerance value has been given by K. z. ~~rgan a:s: 60 micrograms uranium per milliliter of water. All values from the seventeen water samples taken are well within the limits of tolerance, ths highest,.lO micrograms uranium per milliliter of water being 17% of the recommended laval. Fieure 1 shows the fall-off of intensity in Jlg/ml w.i th respect to distance. It can be noted here that although the path or the creek south of the area ~1s not been plotted, the concentration throughout was nil. The figure generally accepted for normal uranium in soil is 4 x 10-6 grams per gram. Of the 50 soil samples analyzed, the values range from nil to 190 tin:es this figure. Figures 2 and 3 show the number of samples takEn at surface and sub-ourface levels and their multiples of normal. Figura 4 contains plots of both surface and sub-ourface soil concentrations west of the fenced area, showing once again, the sharp drop in inte.nsity with distance. Conclusion '!he study revealed the followinit~ 1. The creek vrater samples ware well within the limits of tolel"ance. 2. }.fud samples adjacent to the area ranged in value from nil to 190 times that of normal uranium content in soil. It is felt that a sound conclusion cannot be drawn from the s~9les shown hera because of the unusual conditions that prevailed at the tillB of sampling. Because of the excessive rains, two divergent forces would tend to affect the results. There would be a tendency to a higher result because of tho increased erosion; while the increased quantity of water would tend to dilute 1;be concentration. With comprehensive data the evaluation of hazards presanted by erosion and drainage both into the creek and adjacent area can be more soundly determined. It is thersfore recommended that subsequent soil and liquid samples be taken during essentially dr.y conditions. -2- ------------------- . • '0 t z 3 • ~ ' 1 a O'- 2 l " ~ 6 7 a 9 o 34567891 ~±Tr-: f -:: - ·~ ,: _ + --~-ttt~ -. ~ --- 8 -- • ·. ~ . :!' . .... --~~ ... -.. .• • 1. - : • •. • t . ,;;;. ..: ·, J,.~,·. Figure .3 ,, ...... --- · -"·-~ ·· ___ ...,.. -.~ ....... ._..... _ . ....,._,..... ____ ~ ·-·------·----·-----'"--·--··! , ...... ~ ............... . " ·--· · ···-···.··--·-~ . 'i / -·--·' . ---.. , ·, ., ......... ... -.l Figun 2. ~j."· l.. .t. .· .k i:··":· ... ·- ,· • • • ANAJ,ISE.S Or' Water Samples Taken at Airport Area & Cold ·,rater Creak Robertson, ~ssouri Hlltiples Sample Ur!'niUI!l of pmf. No. Operation Date Description W.crogrami/ml !$vel 1 Airport Area 'J/23/48 Main stream 150 ft. from fence area 4.0 O.O? 2 ,, II " JUnction of stream and Cold ~ter Creek 0.45 o.oos .3 II It II Cold water Creek & Brown Rd . Approx. 250 it. "l from fence 6 . 0 0. 1 ., ... 4 II " II stream near Brown Rd. 10 i't. fran area .3. 5 o.o6 'J 5 II u Stream near Br01!1l Rd. {juncti on with Cold Water Creek) 10.0 0 .17 tt.r:' " I. . 6 II " • 10 ft. from area main stream leading into Cold ~~ Water Creek 7 .0 o.u 7 " " II 100 ft. from area . Stream near Br~tn Rd. 3. 5 o.o6 8 " II It Cold ','l'ater creek at Taylor Rd. Approx. 1 lllile t:: .:. ~., . J down tile creek 0. 015 O. OOOJ 1""' . ~ · 9 n It n Byp&ss 6? - Highl'lay l40 - ~zel'I'IOOd al. o.ooos o.oooo1 t 10 " It 11 Cold uater Creek - t mile N of New Halls Ferry Rd. o.oo10 0.00002 11 II II II Cold Water Creek - Ol d Ferry Ri. 0.0026 0. 00004 l2 II! n II Cold water Creek - Old Jamestown Rd. 0. 0010 . 00002 13 .. n .. Cold water Creek - Junction of Mo. 99 & Highway 67 0. 0020 . 0000.3 14 " II It Cold Water Creek-1m Halls Ferry Rd. & Patterson Rd. o.oo:w . 0000.3 15 " II It Cold water Creek at N• tural Bridge Rd. o.ooos . oooo1 • 16 II " It Cold Water Creek - St. Charles Rd. o.oooo 0 • • 5alnple No. Operation Date l? 18 A.irport. Area J/23/48 " II II aNALYSES OF Water S&mples Taken at Airport Al'aa & Cold Water Creek Robertson, ~s5ouri Description Cold ~t er Creek - ~dland Blvd. M.lltiples Ui~n.1:wn o.i" Pttti • Alicrograms/ml laval o.oooo 0 c:ra'Wfish picked up on area {Ash weight 3.0 grams} 12. )1/gram of ash .. · •r . ..:t I ~ -- ·-- • ANALYSES OF Soil Samples Taken at Airport Area, Robertson, Mo:. l!llti ples Sanple Uranium of nonaal No1 Q.Eeration Date Il!P'th ~ription micrograms tEE,aJn soil Con9_t 1 Airport Area 3/2E/4S Surface l.'ud 6r from S end of area drainage ditch 0 to 311 near railroad o.o 0 2 II II II Mld. .3" to 6tl 6r fran s end of area drainage ditch balOl'l surface near railroad o.o 0 3 11 II Surface mud 201 N of S and of fence 101 W of fence o.o 0 0 to 311 deep 4 !.Ud Jll to 6U 201 N of Send of fence 10' 'IV of fence o.o 0 r. ·.· II It n • deep ,~. · " 5 II II Surface mud .35' N of s end of f ence 101 W of fence o.o 0 ~ : o to 311 ~; . , .. 6 II II " l!l.d .3n to 6n .35 1 N of S end of fence lO' \1 of fence o.o 0 ~:· :"' deep ,. . f ? n 11 Surface mud 60• N from S eoo of fence lO• \'i of fence 3.2 .so 0 t o .311 a q II II MUd 311 to 7u 601 N from B end of fence 10 r 1'l of fence 3.3 .8,3 deep 9 II .. II Surface mud 95' .from S end of Fence 10' ',f of fence 760. 0 to 4" in ditch 190 10 II II II Surface mud 1251 N of SW end of fence 10' W of fence 19. 4.5 0 to 311 ll II II II }Jld 311 to 611 deep 1251 N of ~ end of fence 101 11 of fence 17. 4.3 12 II II II Surface mud 150' N of SW end of fence 10' W of fence l6. 4.0 • 0 to .3" deep • Sample Uranium !Jlltiples o:f no :rmal No. Operation Depth Description micrograms/gram soU Cone. 1;3 Airport Area J/28/48 llud ~~~ to 6" 1501 N of Sli end of .fence 101 Wo! .fenee 17. 4.;3 14 II II II &lrface mud 1801 N of 5W end t:.>£ renee 101 W of
0 to 3″ fence 8.1 2.0
15 n II .. l!ld 3u to 6•- 1801 N of S5. end of fence lOt Wo! o.o 0
fence
16 II II Surface I!Dld 2201 N of SW end of fence 5′ ii of n. 2.8
0 to 3″ fence
17 11 II ” l’!Wi 3″ to 6n 2201 N of SN end of fence 5′ w or o.o 0
beneath surface fence
l8 II ” It lbd 0 to 511 250• N of SW end or fence 101 W of 9 • .3 2.7
deep fence
19 II II Surface mud 10′ N of NW end of fence o.o 0
0 to 4″ deep
..0
20 II It II Surface mud 310′ N of Sif end of fence 101 \’l of o.o 0 I
0 to 411 fence
21 II II Surface md 201 s of Bl’own Rd. 1001 W of fence 12. 3
0 to 311 towards Cold ·,vater Creek
22 1:11 It .. )u to sin deep 100′ W of fenee towards Cold Water 2.1 o.s
Creek 201 S of Brown Rd.
2J II … It 0 to ,311 deep 2001 W of fence towards Cold ·:1ater 1.2 o3
Creek 201 5 of Brown Rd.
24 II II II Ml.d depth 311 2001 W o! fence towards Cold \'{ater o.o 0
to 611 Creek 5′ S ot Brown Rd.
25 II II II Surface I!Dld 275′ :’i o! fence towards Cold Water u. 2.8
0 to .)11 Creek 5′ S of Brown Rd. (Ditch) • 26 •• II It 3″ to 611 deep 275• w of fence towards Cola water
Creek 51 S of Brown Rd. (Ditch)
12. .3
·. – – —· -·- –·
.. – – • MJ.ltiples
$ample Uranium of normal
No . Operation DaUI Depth Desca-iption Mi.crogramB/gram soil cone.
27 Airport Area 3/’)13/413 l.ll.d 0 to Jitt 4501 ll” of fence near Col d Water Creek 5. 0 1. 25
101 from Brown Rd. (Ditch)
;cs II ” ” Surface mud 500′ r f of ~Ff end of fence junction 1. 5 .38
0 to 3 11 deep of ditch and Cold water Creek 10′ N
of Rl.ilroad tra cks
!%
29 l l 11 n 3n to 7 11 deep 500′ \Y of SY: end of fence j unction o.o 0
ot ditch and·. Cold Water Creek 10′ N of Railroad tracks ·J.
30 II It II Surface mud 4001 Vf of Sl'( corner of fence 75′ N 4 – 5 1 .1 :!’
0 to 4″ deep of RR tracks (drainage ditch} : ~~– f:
31 ll II II 411 to 7″ be- 4001 W af S’:l corner of fence 751 N 2.2 .7
neath surface of RR tracks (drainage. ditch) ,.
32 ll II Surface mud 300′ ‘\’:” of S\7 end of fence (drainage 6 .0 1.5 ~ :.
0 to~~
·-·· : ditch) and 591 N of RR t racks . …,
3!11 to 6in 300′ ‘\’f of SW end of fence (drainage 6.
V ‘
33 •• 11 •• .24. I .
deep ditch) 50 1 N of RR tracks
34 II ” • Surface mud 200• W of s’• end oi f ence 751 N of n. 2.7
0 to 3″ 4eep RR tracks (drainage ditch)
35 II ll ” 311 to 6n 200• ‘II oi S’,f end of fence 75′ N of .3·4 .8.5
RR tracks (drainage ditch)
36 n It II 0 to 3″ deep 100′ W of’ SW end a! fence 50′ N o! 50. 12.5
Surface mud RR tracks (s1’lB.Illpy section)
Yl • • Ju to 6!n 1001 W of sn· end of f ence 50• N of ?.9 .2
RR tracks (Sllalllpy section)
38 II II II 0 to 2ttt sur- 1001 7( of srr and of fence 100′ N of 31. s.o
face mud RR tracks (swampy section)
. 39 n It 2~’ to 6~” 100′ w of S1f end of fence 1001 N o! 4. 0 1.0
If deep RR tracks (swampy section)
• MuJ:t.iples
&unple Urani\llll of normal
No. Oper14tion Date Depth Descri;etion :t.:~ crogramsLrz.a.m. soil Cone .
40 Airport ANa 3/2I3/JJ3 0..311 deep sur- 251 W of w fence towards Cold so. 12.5
face !!!.’J.d ~i’il.tar Creak, 200′ H or RR track
(swamp)
41 II 11 II 0…311 deep 201 w of 11 fence towards Cold ·t~ater 65. 16.2
surface mu.d C~ek 1001 1-1 of RR tra.cka (swamp) w: ~-·
42 II It J• to 6- deep 20• W of “f1 fence tor.oards Cold Water ?.1 1.8
Creak 100• N of RR tr&cks (swamp)
43 11 II 11 Surface mud 20• N of SVT end of fence .251 ‘!T of ?! 3.8 .95
0- 2~1 fence towards cold Water Creek
(drainage ditch)
44 II • • 2!11 to stu 201 N of Si’l end of fence 251 vr of Y o.o 0
deep fence t.ONards Cold ‘Nater Creek
(drainage ditch)
45 II 11 0 – 311 deep 110’ s of NW end of fence 251 7f or 38. 9.5
fence towards Cold :rater Creek ··:Sh-‘
Jn to 5~’
– ~
46 II 11 It u o• s of Nlf end of tenoe 251 w of 25. 6.2 ‘ .
deep fence tO”//&.rds Cold !’later Creek
47 ,, It II Surface mud Control Natural Bridge Rli. &. Air- o.o 0
0- .3″ deep port ~. 1 mile fran area
48 • • II 3″-Qn·daep Control Na.turs.l Bridge Rd . P~ Air- o.o 0
port Rd. 1 mile from area
49 11 • tt 9-3” daep sur- Control – 5 miles from Airport o.o 0
face 1111d Area city limits
50 II .. Jn-Ott deep Control – 5 miles fran J..irport o.o 0
Area city l:imits •
.\
‘ .
.. •, ~·
·-
… -.
, …… f’ … ~’ o-;w•….c;.s ICS
r KHOol cK£MtCAl WOR I
lfo4ALL.PtC ‘lor ·~ -~–··

., •
Hip 2

Post

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

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

Post

2010-02-08 – EPA – West Lake Landfill – Missouri radiation cleanup plan 18 times weaker than EPA precedent

WLLFOIA4312 – 001 – 0055919
” cause
a
2
WLLFOIA4312 – 001 – 0055920

Post

2014-05-14 – EPA – West Lake Landfill – Why is EPA not testing drainage ditches at BMAC

To:
From:
Sent:
Subject:
Aboussie, Lou[[email protected]]
Sanders, LaTonya
Wed 5/14/2014 2:47:12 PM
RE: Westlake
Good Morning Lou,
EPA has no validated information indicating the need to screen for radiation outside of the West Lake
Landfill site. We are undertaking a screening of BMAC to allay public concerns at that heavily used
recreation complex. The screening methods EPA will use there have been employed at many sites
across the country and are supported by research and documented procedures. Soil sampling will also
be performed at BMAC to confirm the screening results. In their 2005 Record of Decision the U.S. Army
Corps of Engineers cited extensive Department of Energy sampling of the haul roads. None of the
samples collected exhibited radionuclide concentrations exceeding the proposed surface and subsurface
soil remediation goals identified in the ROD. Soil sampling conducted by MDNR in 2005 in the ditches
and shoulders along Boenker Lane and Taussig Road for radium, thorium and uranium did not identify
any high concentrations of these radionuclides. With regard to screening haul roads, they remain under
the purview of the USAGE FUSRAP program.
—–Original Message—–
From: Aboussie, Lou [mailto:[email protected]]
Sent: Tuesday, May 13, 2014 6:01 PM
To: Sanders, LaTonya
Subject: Re: Westlake
Just curious, does not have to be formal. Thx
—– Original Message —–
From: Sanders, LaTonya [mailto:[email protected]]
Sent: Tuesday, May 13, 2014 06:46PM
To: Aboussie, Lou
Subject: RE: Westlake
Hi Lou,
Working on a response.
—–Original Message—–
From: Aboussie, Lou [mailto:[email protected]]
Sent: Saturday, May 10, 2014 8:35AM
To: Sanders, LaTonya
Subject: Westlake
Why are the drainage ditches at BMAC not going to be tested? LA
WLLFOIA4312- 001 – 0058472

Post

1989-07 – NRC – West Lake Landfill – SITE CHARACTERIZATION AND REMEDIAL ACTION CONCEPTS

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SITE CHARACTERIZATION AND
REMEDIAL ACTION CONCEPTS FOR
THE WEST LAKE LANDFILL
Docket No. 40-6801
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Manuscript Completed: July 1969
Date Published: July 1969
Office of Nuclear Material Safety and Safeguards
_ U.S. Nuclear Regulatory Commission
• Washington, DC 20555
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PREFACE
This report has as its basis a characterization of the West Lake Landfill site
and evaluation of some potential remedial measures performed primarily by
S. K. Banerji, W. H. Miller, J. T. O’Connor and L. S. Uhazy of the University
of Missouri-Columbia. The Nuclear Regulatory Commission received the first
and second drafts, then titled “Engineering Evaluation of Options for Disposition
of Radioactively Contaminated Residues Presently in the West Lake Landfill, St.
Louis County, Missouri,” in 1984; thus most of the information in this report
dates from 1983-1984. However, some more recent data, principally water sampling
results, have been added. Waste disposal and other industrial activities have
continued on the 200 acre site, as have activities in the vicinity, resulting
in changes in details of topography, roads, etc. To provide a more complete
view of the radioactive material in the landfill, use has been made of figures
from the report titled “Radiological Survey of the West Lake Landfill, St. Louis
County, Missouri,” NUREG/CR-2722, May 1982.
The remedial action concepts in this report are those proposed by the contractor.
Judgments expressed in this report about these concepts are in general those of
the contractor, and do not necessarily represent the views of the Nuclear Regulatory
Commission. For example, the cost estimates for these concepts are
based on radium-226 concentrations whereas the long-term issue is dependent
upon the thorium-230 concentrations.
Although some of its information has not been updated since 1984, this report is
being released so as to make its collected information available to interested
parties.
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ABSTRACT
The West Lake Landfill is near the city of St. Louis in Bridgeton, St. Louis
County, Missouri. In addition to municipal refuse, industrial wastes and demolition
debris, about 43,000 tons of soil contaminated with uranium and its radioactive
decay products were placed there in 1973. After learning of the radioactive
material in the landfill, the U.S. Nuclear Regulatory Commission (fJRC) had
a survey of the site’s radioactivity performed and, *n 1983, contracted, through
Oak Ridge Associated Universities (ORAU), with the University of Missouri-
Columbia (UMC) to characterize the environment of the site, conduct an engineering
evaluation, and propose remedial measures. This report presents a description
of the results of the UMC work, providing the environmental characteristics
of the site, the extent and characteristics of the radioactive material there,
some considerations with regard to potential disposal of the material, and some
concepts for remedial measures.
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CONTENTS
Page
PREFACE i i i
ABSTRACT v
SUMMARY 1x
1 INTRODUCTION 1-1
2 SITE DESCRIPTION :’• 2-1
2.1 Location 2-1
2.2 Zoning 2-1
2.3 History 2-2
2.4 Ownership 2-2
2.5 Contaminated Areas 2-2
2.6 Topography 2-3
2.7 Geology 2-3
2.8 Hydrology 2-6
2.9 Meteorology 2-10
2.10 Ecology 2-11
2.11 Demographics 2-14
3 RADIOLOGICAL CHARACTERIZATION OF THE SITE ‘3-1
3.1 Radiological Surveillance 3-1
3.2 Survey Results 3-2
3.3 Estimation of Radioactivity Inventory 3-7
4 APPLICABILITY OF THE BRANCH TECHNICAL POSITION 4-1
5 REMEDIAL ACTION ALTERNATIVE CONSIDERATIONS 5-1
5.1 Option A: No Remedial Action 5-1
5.2 Option B: Stabilization on Site With Restricted
Land Use 5-2
5.3 Option C: Extending the Landfill Off Site 5-4
5.4 Option D: Removing Radioactive Soil and Relocating
It 5-5
5.5 Option E: Excavation and Temporary Onsite Storage in
a Trench 5-6
5.6 Option F: Construction of a Slurry Wall to Prevent
Offsite Leachate Migration 5-8
6 REFERENCES 6-1
CONTENTS (Continued)
FIGURES
1.1 Location of West Lake Landfill 1-2
2.1 Land use around West Lake Landfill site 2-16
2.2 Zoning plan of West Lake area (June 1984) 2-17
2.3 Site topography and extent of contamination 2-18
2.4 Bedrock stratigraphy 2-19
2.5. Location of monitoring wells 2-20
2.6 Soil profile of river alluvium 2-21
2.7 Cross-section of Missouri River alluvial valley 2-22
2.8 Soil profile of upland loessal soil 2-23
2.9 Surface hydrology of West Lake area 2-24
2.10 Average monthly precipitation at Lambert Field
International Airport 2-25
2.11 Wind distribution for West Lake area 2-26
3.1 External gamma radiation levels (November 1980) 3-9
3.2 Location of surface soil samples, Area 1 3-10
3.3 Location of surface soil samples, Area 2 3-11
3.4 Location of auger holes, Area 1 3-12
3.5 Location of auger holes, Area 2 3-13
3.6 Auger hole elevations and location of contamination
within each hole m3-14
3.7 Cross-section B-B showing subsurface deposits in
Area 1 3-15
3.8 Cross-section E-E showing subsurface deposits in
Area 2 3-16
3.9 Rn-222 flux measurements at three locations in Area 2
(1981) 3-17
TABLES
3.1 RMC radionuclide analyses of water samples from the
West Lake site taken by MDNR in 1981 3-18
3.2 Radiological quality of water in perimeter monitoring
wells of West Lake Landfill (concentrations reported
in pCi/1) 3-20
3.3 Radionuclide concentrations in well water samples:
May 7-8, 1986 3-21
3.4 Radionuclide concentrations in Latty Avenue composite
samples 3-26
4.1 Summary of maximum soil concentrations permitted under
disposal options 4-2
5.1 Itemized cost of remedial action, Option B 5-10
5.2 Itemized cost of remedial action, Option C 5-11
5.3 Itemized cost of remedial action, Option D 5-12
vii
CONTENTS (Continued)
TABLES (Continued)
|
5.4 Itemized cost of remedial action, Option E 5-13
• 5.5 Itemized cost of remedial action, Option F 5-14
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SUMMARY
In 1973, approximately 7900 metric tons (mt) (8700 short tons) of radioactively
contaminated barium sulfate (BaS04) residues were mixed with about 35,000 mt
(39,000 t) of soil, and the entire volume was placed in the West Lake Landfill
in St. Louis County, Missouri. This material resulted from decontamination
efforts at the Cotter Corporation’s Latty Avenue plant where the material had
been stored. Disposal in the West Lake Landfill was not authorized by the
Nuclear Regulatory Commission (NRC) and was contrary to the disposal location
indicated in the NRC records. State officials were not notified of this disposal
since the landfill was not regulated by the State at the time. Although
the contamination does not present an immediate health hazard, authorities have
been concerned about whether this material poses a long-term health hazard to
workers and residents of the area and what, if any, remedial action is necessary.
In 1980-81, Radiation Management Corporation (RMC) of Chicago, Illinois,
performed a detailed radiological survey of the West Lake Landfill under contract
to the NRC (NUREG/CR-2722). This survey was performed to determine the
extent of radiological contamination.. Before this survey, little was known
about the location or activity of radionuclide-bearing soils in the landfill.
This survey showed that the radioactive contaminants are in two areas. The
northern area (Area 2) covers about 13 acres. The radioactive debris forms a
layer 2 to 15 feet thick, exposed in only a small area on the landfill surface
and along the berm on the northwest face of the landfill. The southern area
(Area 1) contains a relatively minor fraction of the debris covering approximately
3 acres with most of the contaminated soil buried with about 3 feet of
clean soil and sanitary fill.
The RMC survey showed that the radioactivity is from the naturally occurring
U-238 and U-235 series with Th-230 and Ra-226 as the radionuclides that dominate
radiological impact. The survey data indicate that the average Ra-226 concentration
in the radioactive wastes is about 90 pCi per gram; the average Th-230
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concentration is estimated to be about 9000 pCi per gram. Since Ra-226 has
been depleted with respect to its parent Th-230, Ra-226 activity will increase
in time (for example, over the next 200 years, Ra-226 activity will increase
ninefold over the present level). This Increase in Ra-226 must be considered
in evaluating the long-term hazard posed by this radioactive material.
In addition to RMC’s radiological survey, (oil and water samples were collected
and analyzed by others, Including Oak Ridge Associated Universities (ORAU), and
the University of Missouri-Columbia (UMC). “Occasionally a sample of water from
a monitoring well exceeds slightly the EPA drinking water standard of 15 pCi
gross alpha per liter. Sample analyses for priority pollutants (non-radioactive
hazardous substances) show a number of listed pollutants are present.
On the basis of radiological surveillance conducted by RMC, UMC, and ORAU, the
following areas of concern have been identified:
(1) Radioactive soil is eroding from the northwestern face of the berm, and is
being transported off site.
(2) Radon gas had been observed to accumulate to an unacceptable level
in the Butler-type building on site. This building has since been removed.
(3) Some degree of radiological contamination has been found in the wells
that monitor the perimeter.
(4) Surface exposure rates over much of the contaminated areas are greater
than 20 uR/hr.
In March 1983, the NRC through ORAU, contracted with UMC to conduct an
engineering evaluation of the site and propose possible remedial measures for
NRC’s consideration for dealing with the radioactive waste at the West Lake
Landfill. The following six remedial options were proposed and evaluated in
this study.
o Option A – No remedial action
o Option B – Stabilization onsite with restricted land use
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o Option C – Extending the landfill offsite with restricted land use
o Option 0 – Removal and relocation of the contaminated material to an
authorized disposal site
o Option E – Excavation and temporary onsite storage in a trench
o Option F – Construction of a slurry wall to prevent leachate from
migrating off site
It is noted that some of the above alternatives for remedial action were
initially evaluated with the objective of permanent disposal of the waste at
the site.
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1 INTRODUCTION
The West Lake Landfill is located In St. Louis County, Missouri, 6 km (3.7
miles) west of Lambert Field International Airport (Figure 1.1) and southwest
of St. Charles Rock Road in Bridgeton, Missouri. The site has been used since
1962 for disposing of municipal refuse, industrial solid and liquid wastes, and
construction demolition debris. In addition, the landfill is an active industrial
complex on which concrete ingredients are measured and combined before
mixing (“batching”), and asphalt aggregate is prepared. Limestone ceased to be
quarried in the spring of 1987.
In 1973, 7900 metric tons [(mt) (8700 short tons)] of radioactively contaminated
barium sulfate (BaSD4) residues from uranium and radium processing were mixed
with an estimated 35,000 mt (39,000 tons) of soil and deposited in the West Lake
Landfill. Previously, this material was located at the Cotter .Corporation’s
Latty Avenue facility in Hazelwood, Missouri, and was removed during decontamination
work. It is not known what levels of contamination were already in
the soil before the barium sulfate residues were mixed into it. Disposal in the
West Lake Landfill was unauthorized and contrary to the disposal location
indicated in the U.S. Nuclear Regulatory Commission’s (NRC’s) records.
Subsequently> the NRC sponsored studies that were directed at determining the
radiological status of the landfill. In 1978, an aerial radiological survey
revealed two areas within the landfill where the gamma radiation levels indicated
radioactive material had been deposited. A BOre extensive survey was
initiated in November 1980 by the Radiation Management Corporation (RMC) under
contract to the NRC.
In March 1983, the NRC through Oak Ridge Associated Universities (ORAU) contracted
with the University of Missouri-Columbia Department of Civil Engineering
to describe the environmental characteristics of the site, conduct an engineering
evaluation, and propose possible remedial measures for dealing with the radioactive
waste at the West Lake Landfill. In May 1986, ORAU sampled water from
1-1
Seal* in Miles
Figure l.-l Location of West Lake Landfill
1-2
• wells on and close to the landfill to determine 1f the radioactive material had
• migrated into the groundwater.
Information from all these sources forms the basis for this report.
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2 SITE DESCRIPTION
This chapter presents a historical and environmental description of the West Lake
Landfill site located in St. Louis County, Missouri.
2.1 Location
The 81-hectare (ha) (200-acre) West. Lake Landfill property is situated between
the St. Charles Rock Road and the Old St. Charles Rock Road in Bridgeton,
Missouri. The southeastern and northwestern parts of the landfill abut farmland.
Several commercial and industrial facilities are located near the landfill
(Figure 2.1). The nearest residential area is a trailer park located
approximately 1 km (0.6 mile) to the southeast. A major portion of the landfill
(roughly the northern three-fourths of the site) is located on the
floodplain, approximately 2 km (1.2 miles) from the Missouri River.
2.2
The zoning plan obtained from the Bridgeton Planning and Zoning Department for
properties on and adjacent to the landfill is shown in Figure 2.2. A portion
of the landfill, including site Area 1, is zoned M-l, which is designated for
light manufacturing; the northwest part of the landfill, including Area 2, is
zoned as single-family residential (R-l). This R-l zoning indicates the use to
which the land was originally intended. However, the landfill was extended over
the land zoned R-l, and the zoning plan was simply not changed to reflect the
new usage. Other discrepancies between land use and zoning are found in the
nearby Earth City Industrial Park (William Canney, Safety Supervisor of West
Lake Landfill, Inc., personal communication, March 1984). The land across
St. Charles Rock Road is zoned for light and heavy manufacturing. The
remainder of the property surrounding the landfill is zoned residential and
business.
2-1
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2.3 History
The West Lake Landfill was started in 1962 for the disposal of municipal and
industrial solid wastes, and to fill in the excavated pits from the quarry
operations that had been performed at the site since 1939 (Canney, personal
communication, March 1984). In 1974, the landfill was closed by the Missouri
Department of Natural Resources (MDNR) (Karen, 1976). * new sanitary landfill,
in an area of the West Lake Landfill property which is protected from groundwater
contact, now operates under an MDNR permit.
This new part of the landfill was opened in 1974. The bottom is lined with
clay and a leachate collection system has been installed. Leachate is pumped
to a treatment system consisting of a lime precipitation unit followed in
series by an aerated lagoon and two unaerated lagoons. The final lagoon
effluent is discharged into St. Louis Metropolitan Sewer District sewers.
The quarrying operation ceased in the spring of 1987 because not enough “good
rock” was left at the site.
2.4 Ownership
The West Lake Landfill was owned from 1939 until 1988 by West Lake Landfill,
Inc., of 13570 St. Charles Rock Road, Bridgeton, Missouri. Most of the
landfill was sold in 1988 to Laidlaw Industries, Inc. The two areas which
contain the radioactive material were retained by West Lake Properties as the
principal properties of a subsidiary named Rock Road Industries, Inc.
2.5 Contaminated Areas
Radioactive contamination at the West Lake Landfill has been identified in two
separate soil bodies (Figure 2.3). Comparisons of radionuclide quantities and
of the activity ratios between radionuclides not in secular equilibrium, indicate
that the radioactive contamination in the separate soil bodies was derived from
the same source, i.e., the Cotter Corporation’s former Latty Avenue facility
in Hazelwood, Missouri (NRC, NUREG/CR-2722).
2-2
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The northern area (referred to as Area 2) of contamination shown on Figure 2.3 4*
covers an area of 5.2 ha (13 acres) and lies above 5 to 6 m (16-20 ft) of landfill
debris. The contaminated soil forms a more or less continuous layer from
1 to 4 m (3 to 13 ft) in thickness, and amounts to approximately 100,000 m3
(130,000 yd3). Some of this contaminated soil is near or at the surface,
particularly along the face of the northwestern berm. Beneath the landfill
debris, the soil profile consists of 1 to 2 m (3 to 7 ft) of floodplain top
soil overlying 10 to 15 m (33 to 50 ft) of sand and gravel alluvium.
The southern area of contamination (referred to as Area 1) shown on Figure 2.3
covers approximately 1.1 ha (3 acres) and contains roughly 15,000 m3
(20,000 yd3) of contaminated soil. This body of soil is located east of the
landfill’s main office at a depth of about 1 m (3 to 5 ft), and is located over a
former quarry pit, which was filled in with debris. The depth of debris beneath
the contaminated soil is unknown, but is estimated to be 15 to 20 m (50 to 65 ft).
Limestone bedrock underlies the landfill debris.
2.6 Topography
About 75% of the landfill site is located on the floodplain of the Missouri
River. The site topography is subject to change because of the types of activities
(e.g., landfilling and quarrying) performed there. Figure 2.3 shows a
contour map of the site as of July 1986. The surface runoff follows several
surface drains and ditches which run in a northwest direction and drain into
the Missouri River.
2.7 Geology
2.7.1 Bedrock
Bedrock beneath the West Lake Landfill consists of Mississippian age limestone
of the Meramacean Series of the St. Louis and Salem formations, which extends
downward to an elevation of 58 m (190 ft) mean sea level (msl) (Figure 2.4).*
*Missouri Department of Natural Resources, Division of Geology and Land
Survey, Rolla, Missouri, Well Log Files.
2-3
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The limestone is dense, bedded, and fairly pure except for intermittent layers
which consist of abundant chert nodules. The Warsaw Formation—also of
Mississippian age—lies directly beneath the limestone. The Warsaw is made up
of approximately 12 m (38 ft) of slightly calcareous, dense shale; this grades
into shaley limestone toward the middle of the formation (Figure 2.4) (Spreng,
1961). Bedrock beneath the site dips at an angle of 0.5° to the northeast.
Eight kilometers (5 miles) east of the site, the attitude of the bedrock is
reversed by the Florissant Dome; the bedrock dips radially outward from the
apex of this dome at a low angle (Martin, 1966).
Since karst (solution) activity often occurs in carbonate rocks, the possibility
of its occurrence in the West Lake Landfill area was considered. Brief
observation of the quarry walls at the landfill suggests that some solution of
the limestone has occurred, but this solution activity has apparently been
limited (see Section 2.8.1) to minor widening of joints and bedding planes near
the bedrock surface. Although karst activity within the limestone is relatively
minor, the upper surface of the bedrock is irregular and pitted as a result of
solution (Lutzen and Rockaway, 1971). This alteration of the bedrock surface
is greatest beneath the Missouri River floodplain.
2.7.2 Soils
Soil material in this area may be divided into two categories: Missouri River
alluvium and upland loessal soil. This demarcation is shown as the historical
edge of the alluvial valley in Figure 2.5. The division is made on the basis of
soil composition, depositions! history, and physical properties. Because the
West Lake Landfill lies over this transition zone, the surface material at the
site varies considerably from southeast to northwest.
The Missouri River alluvium (Figure 2.6) ranges in thickness from 12 m (40 ft)
beneath the landfill site to more than 30 m (100 ft) at mid-valley (Figure 2.7).
The upper 3 m (10 ft) of the soil profile consists of organic silts and clays,
that have been deposited by the Missouri River during floods.* Below this
*Missouri Department of Natural Resources, Division of Geology and Land Survey,
Rolla, Missouri, Well Log Files.
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surface layer, the soil becomes sandy and grades to gravel at depths greater
than 5 to 10 m (16 to 33 ft). Because of the effects of channel scour, which
continues to grade the sediment after its initial deposition, the alluvium is
fairly homogeneous in a.horizontal direction and becomes progressively coarser
with depth (Goodfield, 1965). At the edges of the floodplain, the alluvium is
not as well graded, and a large amount of fine material is present in the deeper
sand and gravel.
The upland loessal soil (Figure 2.8) is generally thinner than the floodplain
soil, being usually less than 12 m (39 ft) thick, and was deposited during the
age of Pleistocene glaciation. The loess consists of silt-sized particles that
were transported by wind and deposited as a blanket over much of Missouri and
Illinois. On the hills near the West Lake Landfill, the loess layer may be as
much as 24 m (79 ft) thick. It consists of 6 to 9 m (20 to 30 ft) of fairly
pure silt (Peoria loess) overlying 6 to 15 m (20 to 49 ft) of clay silt (Roxana
loess) (Lutzen and Rockaway, 1971). This loess forms the hills to the southeast
of the landfill, but it has long ago been removed from the landfill site and
most of the surrounding valleys by erosion. The upper 1 m (3 ft) of the loess
has been altered to form a thin soil profile. It should be noted that loess has
a vertical permeability which is far greater than its horizontal permeability
(Freeze and Cherry, 1979). The total permeability of loess is greatly increased
by disturbance. The individual silt grains are generally quite angular, and
therefore may not be effectively compacted by the methods commonly used to consolidate
clay. The technique most effective in the compaction of loess would
employ vibration beneath a surcharge. A relict soil profile from 5 to 10 m
(16 to 33 ft) thick lies beneath the loess and directly on top of the bedrock.
This soil was formed as a residuum before Pleistocene glaciation and was subsequently
covered by the loess blanket. This soil is a highly consolidated
clay containing abundant chert fragments (Lutzen and Rockaway, 1971). In
addition to the natural geologic properties of the landfill, human disturbance
of the soil must also be considered since material within the landfill itself
can either limit or facilitate migration of leachate to the Missouri River
alluvial aquifer.
In order to prevent downward movement of leachate, it is now a common practice
to place a layer of compacted clay beneath sanitary landfills. Newer portions
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of the landfill (constructed since 1974) have 2 to 3 m (7 to 10 ft) of clay at
the base and around the sides. Waste is covered every day with 15 cm (6 in.)
of compacted soil; the cover soil presently used is loess (of soil classifications
CL and A4) taken from southeast of the landfill (Reitz and Jens, 1983a).
If not properly compacted, this material may have a permeability of 0.0001 cm/sec
(0.00004 in./sec) or more. It is not known what procedures for compaction, if
any, were used at the landfill before 1974 since the site was unregulated in
design as well as in materials which were accepted for disposal. J.t is believed,
however, that there is no liner present beneath the northwestern portion
of the landfill, and that sanitary (and, possibly, some hazardous) material
was placed directly on the original ground surface. Since waste was periodically
covered with soil to minimize rodent and odor problems, the landfill
probably consists of discrete layers of waste separated by thin soil layers.
Both areas containing radioactive material are in these presumably unlined g^
above-ground portions of the landfill.
2.8 Hydrology
2.8.1 Subsurface Hydrology
Groundwater flow in the area surrounding the West Lake site is through two
aquifers: the Missouri River alluvium and the shallow limestone bedrock. The
base of the limestone aquifer is formed by the relatively impermeable Warsaw
shale at an elevation of about 58 m (190 ft) msl (Figure 2.4). This shale
layer has been reached, but not disturbed, by quarrying operations. Therefore,
the Warsaw shale acts as an aquiclude, making contamination of the deeper limestone
very unlikely. The Mississippian limestone beds have very low intergranular
permeability in an undisturbed state (Miller, 1977). However, a
strong leachate enters the quarry pit at an elevation of about 67 m (220 ft)
msl (pt. A on Figure 2.5). This leachate is migrating vertically through more
than 30 m (98 ft) of limestone. Explosive detonations associated with quarrying
operations will tend to cause fractures to propagate in the quarry wall. These
fractures have probably extended less than 10 m (33 ft) into the rock from the
quarry face. Beyond this, the rock probably remains undisturbed. These
fractures will tend to increase inflow to the quarry pit and allow leachate to
percolate downward through the fractured zone. Thus, leachate inflow to the
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quarry pit 1s not evidence of large-scale contamination of the limestone
aquifer. The only other mechanism by which leachate could travel’ rapidly
through the limestone is by transport through solution channels. ‘ Landfill consultants
and quarry operators maintain that the limestone is fairly intact
(Canney, personal communication, September 1983), and superficial observation
of the quarry walls seems to support this conclusion. Since the limestone is
fairly impervious, and groundwater flows in most areas from the bedrock into *,
the alluvium, contamination of water in the bedrock aquifer does not appear
likely.
The water table of the Missouri River floodplain is generally within 3 m (10 ft)
of the ground surface, but at many points it is even shallower. At any one
time, the water levels and flow directions are influenced by both the river
stage and the amount of water entering the floodplain from adjacent upland
areas. A high river stage tends to shift the groundwater gradient to the
north, in a direction that more closely parallels the Missouri River. Local
rainfall will shift the groundwater gradient to the west, toward the river and
along the fall of the ground surface. This is inferred from water levels
measured in monitoring wells at the West Lake site. The fact that groundwater
levels commonly fluctuate more than does the Missouri River level, indicates
that upland-derived recharge exerts a great deal of influence over groundwater
flow at the West Lake site. This influence decreases toward the river.
The deep Missouri River alluvium acts as a single aquifer of very high permeability.
This aquifer is relatively homogeneous in a downstream direction,
and decreases in permeability near the valley walls. The deeper alluvium is
covered by 2 to 4 m (7 to 13 ft) of organic silts and clays that may locally
contain a large fraction of sand-sized particles. Water levels recorded between
November 1983 and March 1984 in monitoring wells at West Lake* indicate a
groundwater gradient of 0.005 flowing in a N 30°W direction beneath the northern
portion of the landfill. This represents the likely direction of any possible
leachate migration from the landfill (Figure 2.5).
*Data supplied by Reitz and Jens engineering firm, St.Louis, 1984.
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The alluvial aquifer recharges from upland areas from three sources: seepage
from loess and bedrock bordering the valley, channel underflow of upland streams
entering the valley, and seepage losses from streams as they cross the floodplain.
Of these sources, streams and their underflow represent the main source
of upland recharge to the alluvial aquifer. Streams entering the floodplain
raise the water table in a fan-shaped pattern radiating outward from their point
of entrance to the plain. In areas where streams are not present, the water
slopes downward from the hills, steeply at first and then gently to the level
of the free water surface in the Missouri River channel. The situations described
above do not take into account the effect of variations in permeability
of the shallow soil layer. Aerial photography of the site indicates that a
filled backchannel (oxbow lake) type of soil deposit is present along the southwest
boundary of the landfill (USDA, 1953). This deposit is probably composed
of fine-grained material to the depth of the former channel (6 to 10 m)
(20 to 33 ft). This deposit may tend to hamper communication between shallow
groundwater on opposite sides of the deposit.
Since no other recharge sources exist above the level of the floodplain, the
only water available to leach the landfill debris is that resulting from rainfall
infiltrating the landfill surface. Because the underlying alluvial aquifer
is highly permeable, there will be little “mounding” of water beneath the
landfill. Because the northern portion of the landfill has a level surface it
is likely that at least half of the rainfall infiltrates the surface. The
remaining rainfall is lost to evapotranspiration and (to a lesser degree) surface
runoff. Due to the height of the berm, temporary impoundment of surface
runoff is a common occurrence.
No public water supplies are drawn from the alluvial aquifer near the West Lake
Landfill. It is believed that only one private well (Figure 2.9) in the vicinity
of the landfill is used as a drinking water supply. This well is 2.2 km
(1.4 miles) N 35°W of the former Butler-type Building location on the West Lake
Landfill. In 1981, analysis showed water in this well to be fairly hard (natural
origins) but otherwise of good quality (Long, 1981).
Water in the Missouri River alluvium is hard and usually contains a high
concentration of iron and manganese (Miller, 1977). The amount of dissolved
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solids present in the water of the alluvial aquifer varies greatly; purity
increases toward mid-valley where groundwater velocity is greatest. A water
sample from a well in the alluvium 3 km (1.9 miles) north of the landfill had
a total dissolved solids content of 510 mg/liter and total hardness as CaC03
of 415 mg/liter. Water in the limestone bedrock generally has a hardness
greater than 180 mg/liter as CaC03 equivalent (Emmett and Jeffery, 1968). Total
dissolved solids range from 311 to 970 mg/liter. Water in the limestone aquifer
may contain a large amount of sulfate of natural origin (Miller, 1977).
2.8.2 Surface Hydrology
Because of the extremely low slope of the Missouri River flood plain surface,
precipitation falling on the plain itself generally infiltrates the soil rather
than running off the surface. The only streams present on the floodplain are
those that originate in upland areas. Drainage patterns on the plain
(Figure 2.9) have been radically altered by flood control measures taken to
protect Earth City (Figure 2.1) and by drainage of swamps and marshes. Before
these alterations, Creve Coeur Creek passed just south of the landfill, and
drained a fairly large area. It has since been redirected to discharge into
the Missouri River upstream (south) of St. Charles (Figure 2.9). The-old
channel still carries some water, and empties into the Missouri River 45.2 km
(28 miles) upstream from the confluence with the Mississippi River. Near the
landfill, this stream is usually dry. As it crosses the flood plain, the creek
passes through shallow lakes which provide a more or less continuous flow to
the Missouri River throughout the year. A second stream, Cowmire Creek, crosses
the floodplain east of the site. This stream flows northward and joins a backwater
portion of the Missouri River at kilometer 35.4 (22 miles). Because of
the relationship which exists between river level and groundwater level in portions
of the floodplain near the river, these streams may either lose flow (at
low stage) or gain flow (at high stage).
The present channel of the Missouri River lies about 3 km (2 miles) west and
northwest of the landfill. Early land surveys of this area indicate that
200 years ago the channel was located several hundred meters to the east (toward
the landfill) of its present course (Reitz and Jens, 1983b). The Missouri River
has a surface slope of about 0.00018 (Long, 1981). River stage at St. Charles
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[kilometer 45.2 (mile 28)] is zero for a water level of 126.1 m (413.7 ft) msl
(Reitz and Jens, 1983a). Average discharge of the Missouri River is 2190 m3/s
(77,300 ft3/s), with a maximum flow of 2850 mVs (101,000 ftVs) for the period
of April through July, and a minimum flow of 1140 m3/s (40,300 ft3/s) in January
and December (Miller, 1977). Some average properties of Missouri River water
for the period 1951-1970 were: alkalinity = 150 mg/liter as CaC03 equivalent;
hardness = 209 mg/liter as CaC03 equivalent; pH = 8.1; and turbidity = 694 JTU
(Jackson turbidity unit).
Water supplies are drawn from the Missouri River at kilometer 46.6 (mile 29)
for the city of St. Charles, and the intake is located on the north bank of the
river. Another intake at kilometer 33 (mile 20.5) is for the St. Louis Water
Company’s North County plant (Reitz and Jens, 1983a).
The city of St. Louis takes water from the Mississippi River, which joins the
Missouri River downstream from the landfill. In this segment of the river, the
two flow-streams have not completely mixed and the water derived from the
Missouri River is still flowing as a stream along the west bank of the
Mississippi River channel*. The intake structures for St. Louis are on the
east bank of the river so that the water drawn is derived from the upper
Mississippi.
2.9 Meteorology
The climate of the West Lake area is typical of the midwestern United States,
in that there are four distinct seasons. Winters are generally not too severe
and summers are hot with high humidity. First frosts usually occur in October;
and freezing temperatures generally do not persist past March. Rainfall is
greatest in the warmer months, (about one-quarter of the annual precipitation
occurs in May and June) (Figure 2.10) (NRC, 1981). In July and August, thunderstorms
are common, and are often accompanied by short periods of heavy rainfall.
Average annual precipitation is 897 mm (35.3 in.), which includes the average
annual snowfall of 437 mm (17.2 inches snow). Average relative humidity is 68%,
*Ned Harvey, hydrologist with the USGS, telephone communication, August 1983.
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and humidities over 80% are common during the summer. Wind during the period of
December through April is generally from the northwest; winds blow mainly from
the south throughout the remainder of the year. A compilation of hourly wind
observations shows that although the wind resultant is fairly consistent on a
monthly basis, the wind actually shifts a good deal and is very well distributed
in all directions (Figure 2.11) (NRC, 1981; U.S. Department of Commerce,
1960).
Meteorological data used is from Lambert Field International Airport which is
6 km (3.7 miles) east of the West Lake site. Temperature and precipitation
data are also representative of West Lake. However, because of differences in
topography between Lambert Field and the site, the actual wind directions at
West Lake may be slightly skewed in a NE-SW direction parallel to the Missouri
River valley.
2.10 Ecology
The West Lake Landfill is biologically and ecologically diverse. Rather than a
single ecological system (e.g., a prairie), it is a mosaic of small habitats
associated with
(1) moist bottomland and farmland adjacent to the perimeter berm
(2) poor quality drier soils on the upper exterior and interior slopes
of the berm
(3) an irregular waste ground surface associated with the inactive portion of
the landfill
(4) aquatic ecosystems present in low spots on the waste ground surface
Generally, the natural systems which are present are limited by operations in
the active portion of the landfill and form a corridor along the perimeter berm
from near well site 75 (Figure 2.5), on the Old St. Charles Rock Road, clockwise
to the main entrance to the landfill near well site 68, along St. Charles Rock
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Road. The following observation and descriptions demonstrate the biological
variety of these sites.
The flora of the perimeter berm extending from the southwest clockwise to the
area of the main entrance to the landfill present a series of contrasts. Along
the Old St. Charles Rock Road, the bottom and lower slope of the berm is heavily
influenced by the nearby mature silver maple (Acer saccharinum), boxelder
(Acer negundo). oak (Quercus). sycamore (Platanus). green ash (Fraximus
pennsylvanica). and eastern cottonwood (Populus deltoides) trees associated
with the old channel of Creve Coeur Creek. At the corner, between wells 59 and
60 (Figure 2.5), large silver maple and boxelder trees form a dense stand in the
moist soils at the base of the berm. The density of these trees declines on
this slope extending toward the north (well 61) and the Butler-type Building
corner. The extension of this slope toward the northwest is dominated by a
dense willow-like thicket in which a few eastern cottonwoods and a hawthorn
tree have established. From this northwest corner of the landfill to the
eastern limit of the trees between the landfill and St. Charles Rock Road (well
65), the exterior slope of the berm is dominated by dense stands of small and
large eastern cottonwoods. This latter occurrence reflects the influence of
the well-established eastern cottonwoods and sycamores associated with the permanent
pond just north of this site (Figure 2.9). The ground cover along
these exterior slopes consists of grasses, forbs, plants common to disturbed
areas, seedling cottonwoods, and shrubs. A well-manicured grass groundcover
continues from the limit of the trees to the area around the main entrance of
the landfill and well 68. This vegetation contributes to the partial stabilization
of the steep exterior slopes.
The somewhat drier top and the short, interior slope of the berm, colonized by
prairie grasses such as bluestem (Andropogon). blends into the irregular surface
of the inactive portion of the landfill. Depressions in this surface
allow water to collect and tall grasses, foxtail, and plants characteristic
of disturbed areas [e.g., ragweed (Ambrosia), mullein (Verbascum). pokeweed
(Phytolacca). cinquefoil (Potentilla). sunflower (Helianthus), and plantain
(Plantago)] are replaced by characteristic wetland species [e.g., algae
(Spirogyra). cattails (Typha). sedges (Carex). and smartweed (Polygonium)].
Young eastern cottonwoods are established at several of these wet sites.
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Generally, the surface vegetation of the inactive landfill gives way to barren
waste ground around the Butler-type Building location and the barren terrain
associated with recent landfill activities.
Animals were observed associated with these habitats. Cottontail rabbits
(Sylvilagus) were encountered most frequently and their fecal pellets were observed
on the landfill. Density of fecal material was particularly heavy in
the thickets on the exterior slopes of the perimeter berm. In this regard,
coyote (Cam’s latrans) feces containing rabbit fur were observed. Small mammals
(rodents) were not seen but could certainly be present in these areas. Large
ungulates also were not sighted, but tracks and feces of white-tailed deer indicate
that they utilize the landfill.
The only birds observed were a crow (Corvus). several robins (Turdus). and whitecrowned
sparrows (Zonotrichia leucophrys). This certainly does not reflect the
extent to which birds utilize these habitats, for observations were made early
in the spring. It is readily apparent that returning migratory passerines would
utilize the surface vegetation and berm thickets for nesting, cover, and feed
later in the season. It is also possible that waterfowl could utilize the permanent
ponds on the landfill and adjacent to St. Charles Rock Road. Twelve scaup
(Aythya) and mallards (Anas) were observed on the lagoon which serves as part
of the landfill waste water treatment facility.
Small puddles contained characteristic aquatic invertebrates and at least two
species of amphibians. Casual examination of these shallow waters revealed
three genera of snails (Physa, Lymnaea, Helisoma), an isopod (Asnellus),
cyclopoid copepods, and cladocerans. Aquatic insect larvae were not observed;
however, this does not rule out their presence. The sighting of a bullfrog
tadpole (Rana catesbeiana) and audition of spring peepers (Hyla). indicates
these ponds are utilized as breeding sites. No fish were observed in these
puddles on the landfill surface; however, a dead gizzard shad (Dorsoma cepedianum)
was seen in the pond adjacent to St. Charles Rock Road. The only reptiles
seen were the water snake (Nerodia) and the garter snake (Thamnophis).
Although the northwest inactive portion of the landfill is posted with “No
Trespassing” signs, it was evident that humans do encroach on these habitats.
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Fishing tackle was found tangled in power lines and trees, and spent smallgauge
shotgun shells were found on the landfill surface and berms.
2.11 Demographics
The West Lake Landfill is located in the northwestern portion of the city of
Bridgeton, in St. Louis County, Missouri. Earth City Industrial Park is located
on the floodplain 1.5 to 2 km (0.9 to 1.2 miles) northwest of the landfill.
Population density on the floodplain is generally less than 10 persons per
square kilometer (26 persons per square mile); and the daytime population
(including factory workers) is much greater than the number of full-time residents.
Major highways in the area include Interstate 70 (1-70) and Interstate 270
(1-270), which meet south of the landfill at Natural Bridge Junction (Figure
1.1). The Earth City Expressway and St. Charles Rock Road lie, respectively,
west and east of the landfill. The Norfolk and Western Railroad passes about
1 km (0.6 mile) from the northern portion of the landfill (Figure 1.1). Lambert
Field International Airport is located 6 km (3.7 miles) east of the West Lake
Landfill.
In addition to factories at Earth City, plants are operated by Ralston-Purina
and Hussraan Refrigeration across St. Charles Rock Road. The employees of
these two plants probably comprise the largest group of individuals in close
proximity to the contaminated areas for significant periods of time. The
Ralston-Purina facilities are located 0.4 km (0.2 mile) northeast of the
Butler-type Building location at the landfill. Considering that land in this
area is relatively inexpensive and that much of it is zoned for manufacturing,
industrial development on the floodplain will likely increase in the future.
Two small residential communities are present near the West Lake Landfill.
Spanish Lake Village consists of about 90 homes and is located 1.5 km (0.9 mile)
south of the landfill, and a small trailer court lies across St. Charles Rock
Road, 1.5 km (0.9 mile) southeast of tf- site (Figure 2.1). Subdivisions are
presently being developed 2 to 3 km (1.2 to 1.9 miles) east and southeast of the
landfill in the hills above the floodplain. Ten or more houses lie east of the
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landfill scattered along Taussig Road. The city of St. Charles is located
north of the Missouri River at a distance greater than 3 km (1.9 miles) from
the landfill.
Areas south of the West Lake Landfill are zoned residential; areas on the
other sides are zoned for manufacturing and business (Figure 2.2). Most of
the landfill is zoned for light manufacturing (M-l). However, approximately
0.3 km2 (0.12 mi2) of the northern portion of the landfill is zoned for residential
use; this includes the contaminated area around the Butler-type Building
site. The field northwest of the landfill between Old St. Charles Rock Road
and St. Charles Rock Road 1s under cultivation. Trends indicate that the
population of this area will increase, but the land will probably be used
primarily for industrial facilities.
2-15
CARTH city
INDUSIRIAl PARK
Figure 2.1 Land use around West Lake Landfill site
ZOMINO CODE:
R
B
UOIMO:
MIWf»CtuX
N
l«cond«nr Ho*4
Zoning •oundcry
UnMIl i««B
I Warsaw
Lithology
Surface at
West Lake
/
I /
/
I
/
^ I
o I «=.
I I
• (*•• • •
%•• •••(•
I \ r i
/ I
1 \ i
i i i i
if 1 ^ ^» i ^ ^
i*i / T^ i1 i
=3.”=^=5C ^ f 1 ^
‘ 1 1
1 1 1
1 1
1 1 1
1 1 /’ I
1 1 / ^-B
Description
of material
Thick
bedded.
slightly
dolomitic
Iim8stone>
Intact with
little
solution
activity
apparent.
Thin
bedded .. limestone,
at top of
i #«•••• «•*
Some chert
and shale
present.
Dense shale,
calcareous
at top of
formation.
Figure 2.4 Bedrock stratigraphy
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MISSOURI RIVER
FLOODPLAIN
LEGEND:
——— Landfill Boundary
B«rm
O Monitoring Wall
A LMchat* Collection
Well
100m 200m 300m 400m
87
O
WEST LAKE
LANDFILL
HISTORICAL EDGE OF
ALLUVIAL VALLEY
O90
80
$60
O52
061
Figure 2.5 Location of monitoring wells
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1
Overall
permeability
increases
il\\\
Soil
composition
• • ^ , ^™ • • — •
•^ * • * ^
— .” * ~ * . •
‘ o ‘• e . . • ‘ . . ‘
. * ” ” • * * • •
• ‘ . ‘ . ” . • v ”
* • * » • *
‘ • . * ‘ *
. o •’
• e • … «
• * *
:. ‘.’•’. ‘.:”’• •’
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^ 1
1
1 1 1
1 11
1 1 1
Thickness
meters
(feet)
2 – 3
(6.6 • 10)
6-27
(20 • 89)
Description
Silt; clayey at
surface, sandy
at depth
Silty sand
Sand with some
gravel
Sandy gravel
Limestone
bedrock
1
1
1 Figure 2.6 Soil profile of river alluvium
– 2-21
1
rvi
i
rvj
K>
ELEVATION
(ml (ft) NORTHWEST
ISO
140
130
120-
110-
100 H
90 -J
SOUTHEAST
WEST LAKE
«*>-(V MISSOURI LANDFILL
RIVER
.. . CHANNEL
MISSOURI RIVER FLOOD PLAIN
SHALLOW FLOOD PLAIN ALLUVIUM
(Sand and Gravel)
LIMESTONE
BEDROCK
300
Figure 2.7 Cross-section of Missouri River alluvial valley
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Ill
•= 01
11! i E •
ill
Soil
composition
<-*- ^- A-/ ttg&R •V_- ^ r^~r ^rT-&lr ^'^l Thickness meters (feet) 2 3 (6.6 • 10) 6 - 9 (20-30) 6- IS (20 - 50) 5- 10 (17 - 33) Description Organic silts and clays (topsoil) Peoria loess, silt Roxana loess, silty-clay Well-consolidated clay residium Limestone bedrock Figure 2.8 Soil profile of upland loessal soil 2-23 ro i IVJ Sect* 1 24.000 LIOfNO: ^0) Standing WMW •"-**"• P«M>nl«l SlrMm
CITY OF
ST. CHARLES
Figure 2.9 Surface hydrology of West Lake area
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Figure 2.10 Average monthly precipitation at Lambert Field
International Airport
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NNW NNE
3.62m/•
WNW
4.92m/s
3.53m It
3.80m/•
w 4.34m/s
wsw
B.3%\4-6%/3.2%
0.04m/t
6.2% I (calm) | 3.9%
3.8%
4.07m/•
3.89m/•
4.20m/s
sw SE
SSW
ENE
ESE
Wind rose is for Lambert Field International Airport,
Hazelwood, Missouri, and shows the percentage of hourly
observations in each direction along with the average
speed in that direction; for example: wind blew from
the north 4.5% of the time at an average speed of 3.76 m/s.
Figure 2.11- Wind distribution for West Lake area
2-26
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I 3 RADIOLOGICAL CHARACTERIZATION OF THE SITE
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3.1 Radiological Surveillance
Approximately 43,000 mt (47,000 tons) of contaminated soil were reported to have
• been disposed of in the landfill. A fly-over radiological survey performed for
• .the NRC in 1978 identified two areas of contamination at the West Lake Landfill.
I Subsequently, from August 1980 through the summer of 1981, the Radiation
Management Corporation (RMC), under contract to the NRC, performed an onsite
| evaluation of the West Lake Landfill (NRC, NUREG/CR-2722). The purpose of this
survey was to clearly define the radiological conditions at the landfill. The
• results were to be utilized in performing an engineering evaluation to determine
if remedial actions should and could be taken.
The area to be surveyed was divided into 10-m (33-ft) grid blocks and included
• the following measurements:
1 (1) external gamma exposure rates 1 m (3.3 ft) above the surfaces and betagamma
count rates 1 cm (0.4 in.) above surfaces
g (2) radionuclide concentrations in surface soils
• (3) radionuclide concentrations in subsurface deposits
• (4) gross activity and radionuclide concentrations in surface and subsurface
water samples
• (5) radon flux emanating from surfaces
• (6) airborne radioactivity
| (7) gross activity in vegetation
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3.2 Survey Results
External Gamma
Figure 3.1 shows the two areas of elevated external radiation levels as they
existed in November 1980, at the time of the preliminary RMC site survey. As
can be seen, both areas contained locations where levels exceeded 100 uR/hr at
1m (3.3 ft). In Area 2, gamma levels as high as 3000 to 4000 uR/hr were
detected. The total areas exceeding 20 |jR/hr were about 1.2 ha (3 acres) in
Area 1 and 3.6 ha (9 acres) in Area 2.
External gamma levels measured in May and July of 1981 decreased significantly,
especially in Area 1, because approximately 1.2 m (4 ft) of sanitary fill was
added to the entire area and an equal amount of construction fill was added to
most of Area 2. As a result, only a few hundred square meters (a few thousand
square feet) in Area 1 exceed 20 uR/hr. In Area 2, the total area exceeding
20 uR/hr decreased by about 10%, and the highest levels were about 1600 uR/hr,
near the location of the Butler-type building.
Surface Soil Analyses
A total of 61 surface soil samples were gathered and analyzed on site for gamma
activity. Samples were normally stored 10 to 14 days to allow ingrowth of radium
daughters. Concentrations of U-238, Ra-226 (from Pb-214 and Bi-214), Ra-223,
Pb-211, and Pb-212 were determined for each sample. Surface soil samples are
located in Figures 3.2 and 3.3.
In all soil samples, only uranium and/or thorium decay chain nucTides and K-40
were detected. Offsite background samples were on the order of 2 pCi/g Ra-226.
Onsite samples ranged from about 1 to 21,000 pCi/g Ra-226, and from less than
10 to 2100 pCi/g U-238. In those cases where elevated levels of Ra-226 were
detected, the concentrations of U-238 were generally anywhere from a factor of
2 to 10 lower. In cases of elevated sample activity, daughter products of both
U-238 and U-235 were found.
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In general, surface activity was limited to Area 2, as indicated by surface
beta-gamma measurements. Only two small regions in Area 1 showed contamination;
both were near the access road across from the site offices.
In addition to onsite gamma analyses, 12 samples were submitted to RMC’s radiochemical
laboratories for thorium and uranium radiochemical determinations. The
results show all samples contain high levels of Th-230. The ratio of Th-230 to
Ra-226 (Bi-214) is about 20 to 1.
Subsurface Soil Analysis
Subsurface contamination was assessed by extensively “logging” holes drilled
through the landfill. Several holes were drilled in areas known to contain contamination,
then additional holes were drilled at intervals In all directions
until no further contamination was encountered. A total of 43 holes were
drilled, 11 in Area 1 and, in Area 2, 32 including 2 nearby offsite wells for
monitoring water. All holes were drilled with a 6-in. auger and lined with 4-in.
PVC (polyvinyl chloride) casing. The location of these auger holes is shown in
Figures 3.4 and 3.5.
Each hole was scanned with an Nal(Tl) detector and rate meter system for an
initial indication of the location of subsurface contamination. On the basis
of the initial scans, 19 holes were selected for detailed gamma logging using
the intrinsic germanium (IG) detector and multiple channel analyzer.
The results of the Nal(Tl) counts and IG analyses show concentrations of Bi-214,
as determined by the IG system, ranged from less than 1 to 19,000 pCi/g. For
those holes where both Nal(Tl) counts and IG counts were made, a good correlation
between gross Nal(Tl) counts and Ra-226 concentrations, as determined by
in situ analysis of the daughter Bi-214 by the IG system, was found.
It was determined that the subsurface deposits extended beyond areas where surface
radiation measurements exceeded 5 pCi/g. The approximate area of subsurface
contamination compared to the area of elevated surface radiation levels shows a
total difference in areas of 2 ha (5 acres).
3-3
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The variations of contamination with depth for Areas 1 and 2 are shown in
Figure 3.6. As can be seen, the surface elevations vary by about 6 m (20 ft),
and the highest elevations occur at locations of fresh fill. Contamination
(>5 pCi/g Ra-226) in several areas is found to extend from the surface to
appreciable depths, about 6 m (20 ft) below the surface in two cases. In
general, the subsurface contamination appears to be a continuous single layer,
ranging from 0.6 to 4.6 m (2 to 15 ft) thick, located between elevations of 139
to 144 m (455 to 480 ft) and covering 6.5 ha (16 acres) total area.
In Figures 3.7 and 3.8, representations of the subsurface deposits are provided
on the basis of auger hole measurements. These representations are consistent
with the operating history of the site, which suggests that the contaminated
material was moved onto the site and spread as cover over fill naterial. Thus,
one would expect a fairly continuous, thin layer of contamination, as indicated
by survey results.
Nonradiological Analysis
Six composite samples were submitted to RMC’s Environmental Chemistry Laboratory
for priority pollutant analysis. Five samples were taken from auger holes
(one from Area 1 and four from Area 2) and the sixth from the West Lake leachate
treatment plant sludge. The results indicate a significant presence of
organic solvents in Area 2 samples. The results of the leachate sludge
analysis were not as high as any of the soil samples.
A chemical analysis of radioactive material from both areas was also performed
by RMC’s laboratory. Results show elevated levels of barium and lead in most
cases.
Background Radioactivity Measurement
Various offsite locations were selected for reference background measurements.
The results of these measurements were within the normal range.
3-4
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Airborne Radioactivity Analyses
Both gaseous and particulate airborne radioactivity were sampled and analyzed
during this study. Since it was known that the buried material consisted partially
or totally of uranium ore residues, the sampling program concentrated on
measuring radon and its daughters in the air. Two methods were used: the first
was a scintillation flask method for radon gas and the second was analysis of
filter paper activity for particulate daughters.
A series of grab samples using the accumulator method were taken between May
and August of 1981. A total of 11! samples from 32 locations was collected.
Measurable radon flux levels ranged from 0.2 pCi/m2s in low background areas
to 865 pCi/m2s in areas of surface contamination.
At three locations, repetitive measurements were made over a period of 2 months.
These results are plotted in Figure 3.9. As can be seen, significant fluctuations
were observed at two locations. The fact that these fluctuations were
real and not measurement artifacts was later confirmed by duplicate charcoal
canister samples, as described below.
A total of 35 charcoal canister samples was gathered at 19 locations over a
3-month period. The results show levels ranging from 0.3 pCi/m2s to 613
pCi/m2s. On 24 different occasions, the charcoal canisters and accumulator
were placed in essentially the same locations, at the same time, for duplicate
sampling. The results of this side-by-side study show generally good
correlation between the two methods.
A set of 10-minute high-volume particulate air samples was taken to determine
both short-lived radon daughter concentrations and long-lived gross alpha
activity. The highest levels were detected in November 1980, near and inside
the Butler-type building which has since been removed. These two samples
approximately equal NRC’s 10 CFR Part 20, Appendix 6, alternate concentration ‘
limit of one-thirtieth WL for unrestricted areas.
In addition to the routine 10-minute samples, five 20-minute high-volume air
samples were taken and counted immediately on the IG gamma spectroscopy system
3-5
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to detect the presence of Rn-219 daughters. All samples were taken near surface
contamination. In addition to Rn-222 daughter gamma activities, Rn-219
daughters were detected by measuring the low-abundance gamma rays of Pb-211.
Concentrations of Rn-219 daughters ranged from 6 x 10-11 to 9 x 10-10 uCi/cc.
Vegetation Analysis
Vegetation samples included weed samples from onsite locations and farm crop
samples (winter wheat) near the northwest boundary of the landfill. This location
was chosen because runoff from the fill onto the farm field was possible.
No elevated activities were found in these samples. ^
Water Analyses
A total of 37 water samples was taken: 4 in the fall of 1980, and the remainder
in the spring and summer of 1981. One sample was equal to the U.S. Environmental
Protection Agency (EPA) gross alpha activity standard for drinking water of
15 pCi/liter and that was a sample of standing water near the Butler-type
building. Several samples, including all the leachate treatment plant samples,
exceeded the EPA drinking water screening level for gross beta which would
require isotopic analyses. Subsequent isotopic analyses indicated that the
beta activity could be attributed to K-40. None of the offsite samples 4.
exceeded either EPA standard or screening level.
In 1981, MDNR collected 41 water samples which RMC analyzed for radioactivity
(Table 3.1). Of these samples, 5 were background, 10 were onsite surface
water, 10 were shallow groundwater standing in boreholes, and 16 were landfill
leachate. From these data, background activity is estimated as 1.2 pCi/liter
gross alpha and 27 pCi/liter gross beta. Results in Table 3.1 show the
gross alpha in two water samples exceeded or equaled 15 pCi/1; the gross beta in
ten water samples exceeded 50 pCi/1. Most of the gross beta activity comes from
7 naturally occurring K-40 as determined from subsequent isotopic analysis.
In addition, groundwater samples in perimeter monitoring wells at the West
Lake Landfill were taken by UMC personnel and ORAU in 1983, 1984, and 1986.
The well locations are shown in Figure 2.5 and the results are presented in
3-6
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Tables 3.2 and 3.3. Results in Table 3.2 show the gross alpha in two water samples
slightly exceeded 15 pCi/1; the gross beta were all below 50 pCi/1 in all water
samples. Table 3.3 shows analyses were below 15 pCi/1 for gross alpha and 50 pCi/1
for gross beta for all the wells.
3.3 Estimation of Radioactivity Inventory
In examining the RMC report for bore hole samples (Table 3.3), it is noted that
the naturally occurring U-238 to Th-230 to Ra-226 equilibrium has been disturbed.
The RMC report (NRC, NUREG/CR-2722) indicates that the ratio of Ra-226 to U-238
is on the order of 2:1 to 10:1. This observation is consistent with the history
of the radionuclide deposits in the West Lake Landfill, i.e., that they came
from the processing of uranium ores to extract the uranium content and that the
radioactive material at West Lake came from the former Cotter Corporation
facility on Latty Avenue (presently occupied by Futura Coatings Company) in
Hazelwood, Missouri. This location contains contamination from ore processing
residues from which uranium had been previously separated, leaving the daughters
behind at relatively higher concentrations. Additionally, it is noted in the
RMC report that the ratio of Th-230 to Ra-226 is on the order of 5:1 to 50:1.
This indicates that radium has also been removed. Other data are available in
the Latty Avenue site study (Cole, 1981). Table 3.4 presents the radionuclide
concentrations in Latty Avenue composite samples.
Using the RMC data and averaging the auger hole measurements over the two volumes
of radioactive material found in Areas 1 and 2, a mean concentration of 90 pCi/g
was calculated for Ra-226. Also, the ratios of Th-230 to Ra-226 were established
since the level of Th-230 will determine the increase of Ra-226 with
time. Although the ratio of Th-230 to Ra-226 ranged from 5:1 to 150:1, most of
the data were in the 30:1 to 50:1 range. To ensure conservatism in estimating
the long-term effects of Ra-226, a ratio of 100:1 was used for all further
calculations.
Using the Th-230:Ra-226 ratio of 100:1, the Th-230 activity is 9000 pCi per
gram. If the U-238 concentration (as well as U-234 which would be similarly
separated from the ore) is a factor of 5 less than Ra-226, this implies about
18 pCi U-238 per gram. The total mass of radioactive material (having Ra-226
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concentrations of 5 pCi/g or more) In the landfill was estimated by visually
integrating the volume of radioactive material from graphs and multiplying by
an average soil density, resulting in 1.5 x 1011 grams (150,000 metric tons) of
contaminated soil. These numbers indicate that there are about 14 Ci of Ra-226
contained with its decay products in the radioactive material in the landfill.
The material also contains about 3 Ci each of U-238 and U-234, and about 1400 Ci
of Th-230. These estimates indicate the order of magnitude of the quantities
to be dealt with, although the estimate for Th-230 is regarded as conservatively
large.
3-8
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ST. CHARLES ROCK ROAD
Source: NUREG/CR-2722, Figure 3, p. 27.
Figure 3.1 External gamma radiation levels (November 1980)
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Source: NUREG/CR-2722, Figure 7, p. 31.
Figure 3.2 Location of surface soil samples, Area 1
to
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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

1988-05-25 – NRC – Classification of West Lake Landfill

WESTLAKE LANDF1I.T.
Classification: Class III, Priority 14
Site Name: Westlake Landfill
Address: Bridgeton, MO 63042 Between Old Rock Hill Road and New
Rock Hill Road east of Earth City, St. Louis County
T 46 N, R 5 E, St. Charles Quadrangle
Waste Type: radionuclides
Quantity: 7000 tons of low level uranium ore wastes
Site Description:
The site is part of an active landfill on the Missouri River floodplain in
St. Louis County.
Present Owner: Westlake Landfill, Inc.,
Bridgeton, MO 63042
Environmental Problems Related to Site:
The site is an active permitted landfill which in the past accepted 7000
tons of low level uranium ore wastes. Excavation at the site in the past
reached the same depth as the groundwater. There is potential for
contamination of groundwater and the Missouri River which is less than one
mile away, directly west of the site.
Remedial Actions at Site:
The site was surveyed prior to expansion in order to separate the
demolition fill area from the area identified «s containing hazardous
materials.
The Missouri Department of Natural Resources is the lead agency for this
site.
Area of Concern Related to Site:
The average natural ground elevation is 435 to 440 foot with groundwater
at a shallow depth. The alluvium underlying tho river is one of the most
important aquifers in the state. Consequently, If contamination is
occuring from the landfill, it is threatening a vital aquifer resource.
General Geologic and Hydrologic Setting:
LOCATION: Longitude 90 26′ 45″; latitude 38 46′ 15″, St. Charles
Quadrangle.
141
Private wells located near the landfill may nlso ho susceptible to
contamination.
Health Assessment:
Uranium is reported to cause adverse health effects in two ways: toxic
chemical effects including damage to the kidney and liver, pneumoconiosis,
pronounced changes in the blood ?nd generalized injury; and radiation
effects including lung cancer, o^teosarcoma, and lymphoma.
Analysis of the rates of fetal :;iat.h, low birth weight, and malformations
for 1972-1982 showed no rate for the area significantly higher than the
state average.
An exposure assessment including a well survey, water sampling, and an
administrative exposure questionnaire was completed for the site. This
investigation by the Missouri Department of Health has found there are
only four wells still in use in the area that are downgradient from the
site. One is used only occasionally and one is not used for potable water
at all. None of the residents questioned appeared to have any adverse
health effects caused by materials disposed of fit the site.
Based on available information, a health threat exists due to the effects
of low level uranium wastes buried at the site, and the possibility that
off-site migration of these materials might occur. While there is no
evidence of past or present exposure, the potential for future exposure
exists based on the possibility that off-site migration might occur.
Sampling and corrective containment and diversion should continue at this
site until risk to the public health can more accurately be determined.
143

Post

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

UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D. C. 20555
1 ” 1983
MEMORANDUM FOR: Richard E. Cunningham, Director
Division of Industrial and Medical Nuclear Safety
Office of Nuclear Material Safety & Safeguards
FROM: Stuart A. Treby, Assistant General Counsel for
Rulemaking £ Fuel Cycle,
Office of the General Counsel
SUBJECT: WEST LAKE LANDFILL
In your memorandum of January 29, 1988 you requested advice as to the
legal resources avai.lable to the NRC to require a. former licensee, the Cotter
Corporation, to properly dispose of radioactive wastes dumped In the West
Lake landfill on the outskirts of St. Louis, Missouri.
The background information accompanying your memorandum shows that the
radioactive material, seven tons of uranium, was contained in some 8700 tons
of barium sulfate mixed with about 39,000 tons of soil. It was moved to the
landfill between July and October 1973 from the Latty Avenue site which had
been used by the licensee to dewater uranium processing residuals purchased
from the AEC prior to shipment to the licensee’s uranium processing mill at
Canon City, Colorado, for further processing. The operations at Latty
Avenue were carried out under a source material license, SUB-1022, which
was subsequently terminated. It is also abundantly clear that the AEC was
fully aware in 1974 of the admixture of the barium sulfate with soil and its
transfer to the landfill. See letter of November 1, 1974 from John G. Davis,
Deputy Director for Field Operations, Directorate of Regulatory Operations,
to Cotter Corporation.
Mr. Davis1 letter noted that, “The disposal does not appear to be within the
intent of the Commission’s regulations, 10 CFR Part 40, to allow alteration of
the physical nature of Source Material (i.e., dilution of solids with
nonradioactive source material) in order to obtain a physical mixture which
would no longer be subjected to licensing by the Commission.” An inspection
report, No. 040-8035/74-01, transmitted on May 17, 1974 identified the same
transfer of material to the landfill as a disposal contrary to the requirements
of 10 CFR 20.301. There does not appear to have been any follow up
enforcement action by either the AEC or the NRC to these two apparent
violations of regulations.
It is a foregone conclusion that the usual enforcement procedures of the
NRC, that is, a notice of violation or order to show cause leading eventually
to a civil penalty, would be of no avail in this case. In Secy-85-285 the
General Counsel and the Executive Director of Operations (for the Executive
Legal Director) provided a legal analysis of the application of 28 U. S. C.
2462, a federal statute of limitations, to enforcement action of the NRC. The
– 2 –
conclusions of that legal analysis, when applied to the facts of this case,
clearly Indicate that any administrative enforcement action that could or
would result in a civil fine, penalty or forfeiture, is barred by the five year
limitation on actions In that statute. The five year period commences to run
from the time of the violation. In this case that is October 1973, at the
latest. Accordingly, normal enforcement action by the NRC leading to civil
penalty would have been barred after the end of October 1978.
The only effective resource available to NRC at this point in time would be
judicial action under Section 232 of the Atomic Energy Act of 1954, as
amended. Section 232 authorizes the NRC, through the Attorney General, to
seek injunctive relief with respect to violations of regulations or orders.
This would, of course, draw into question whether an order to clean up the
landfill (if that action were to be selected to establish a basis for injunctive
relief) was lawful, as well as if the other necessary bases for injunctive
relief were met, for example, that no other remedy was available, and that
the health and safety hazard warranted judicial intervention. The question
of the lawfulness of the order would likely turn upon the question of
whether there was indeed a violation of regulations in sending the material to
the landfill. Whether there was a violation of 10 CFR 20.301, as stated In
the inspection report, depends upon how 10 CFR 40.13(a) is construed. We
note that there is nothing in that section or elsewhere in 10 CFR Part 40
that expressly prohibits dilution of source material in a mixture to below .05
weight percent in order for it to be exempted from the regulations In Part
40. If exempt, the requirement for transfer to an authorized recipient
would not apply. (See attached memorandum from W. Olmstead to J.
Lieberman) Thus, the licensee could argue that the dilution with soil was
legal and that the transfer and subsequent disposal were legal.
Although the doctrine of laches (a doctrine of repose applied in equity
cases, such as injunction proceedings, analogous to a statute of limitations)
does not apply to the United States Government, the fact that 14 years has
elapsed since the AEC/NRC had evidence of the disposal, and had considered
it a possible violation, argues against the need for immediate vigorous
enforcement through a judicial injunction. Added to this is the fact that the
AEC/NRC terminated the license with full knowedge of the disposal. One
could argue that the responsible regulatory agency, in terminating the
license without further enforcement action, haa determined that the alleged
violations were without merit. Finally, the United States has an alternative
The interpretative problems associated with 10 CFR 40.13(a) are
severe. We have not been able to find anything in its rulemaking history to
support a conclusion that it prohibits dilution, or that it is strictly limited to
chemical mixtures, solutions, alloys, or compounds, under a restrictive
definition of chemical. For example, chemical solutions, compounds, mixtures
and alloys could arguably be limited to those produced by or used in a
chemical process. Thus, the barium sulfate plus uranium would be a
chemcial mixture, but separated uranium subsequently admixed with ordinary
soil would not.
– 3 –
statutory remedy. Uranium is a hazardous substance under CERCLA
(Superfund) and the response authority under Section 104 of that Act could
be invoked.
If the staff determines upon proceeding judicially. Section 161c of the Atomic
Energy Act would authorize the NRC to conduct the necessary studies and
evaluations to support any order to be issued and any subsequent request
for enforcement of the order by judicial injunction. If EPA was to be
requested to proceed under Section 104 of CERCLA then EPA would initiate
the necessary studies and evaluations and supervise the remedial action. We
note that under CERCLA, EPA is not required to litigate responsibility
before proceeding. Under CERCLA, litigation comes after the fact and is
focused upon collection of agency remedial action costs and penalties
from responsible parties.
Stuart A. Treby, Assistant General
Counsel for Rulemaking 6 Fuel
Office of the General Counsel
Cycle
Attachments:
As stated

Post

1992-10-29 – NRC – West Lake Landfill – McLaren Hart – Summary Report – Analysis

cn\<\ M E M O R A N D U M DATE: October 29, 1992 TO: Designated PRP Group West Lake Landfill Site FROM: McLaren/Hart Ray Forrester Brent Finley Jack Buddenbaum SUBJECT: NRC SUMMARY REPORT - ANALYSIS •1> 07 996^7
3. o
40249243
SUPERFUND RECORDS
Several key issues arise from the manner in which the radiological data have been
interpreted in the U.S. Nuclear Regulatory Commission (NRC) Summary Report concerning
the West Lake Landfill Site. This Memorandum briefly reviews the data that have been
collected, examines how that data have been interpreted, and identifies certain overestimates
on the part of the NRC concerning the nature and extent of radioactive contamination at
the Site.
NRC’s Beliefs Concerning Current and Future Health Risks
The NRC documents reviewed state that, under current conditions, the Site does not pose
a risk, nor has it in the past; however, those documents state that, in the future, levels of
radioactivity in soils located at the Site will eventually reach levels that pose a risk and,
therefore, remediation is required to protect against future risks. Indeed, the documents
conclude that levels of radioactivity will reach such magnitudes that on-site cleanup options
may not be feasible and that a costly off-site disposal option may be the only alternative.
These conclusions are based primarily on soil data that was collected over 10 years ago. A
careful review of the surficial and subsurficial boring data, and NRC’s interpretation of
those data, suggests that the radioactive inventory at the Site may have been exaggerated
to the point where the feasibility of less costly options, including no action, may have been
prematurely dismissed and may very well be acceptable for much of the material at the Site.
Data Collection and Interpretation
Briefly, the NRC contractor measured gamma emissions in 18 subsurface borings placed in
areas that were believed to be the most contaminated. The estimates of average levels of
Ra, Th and U and the total radioactive inventory were derived from the information
obtained from these subsurface borings and from approximately 10 surface samples. It is
interesting to note that the subsurface borings data showed that 7 of the 18 borings did not
Westlake Landfill
October 29, 1992
Page 2
have a single sample greater than background concentrations (>2.5 pCi/g Ra), and the
other 5 borings had levels above background only in the top 3 feet. Only the remaining 6
borings had levels of radioactivity that could be considered to be above background
throughout the boring. Apparently, the Site contains localized confined “hot spots”; it is not
contaminated in a homogeneous fashion.
The NRCs interpretation of the data collected, and its assumptions can be summarized as
follows:
Assumption #1: The average specific activity of Ra in all samples from all
of the borings is 90 pCi/g.
Assumption #2: Radiochemical analyses of 10 surface samples showed that
all Th:Bi ratios ranged from 4:1-40:1; other samples taken at Latty Avenue
reportedly had ratios ranging up to 300:1. As a conservative measure, it was
assumed by NRC that the average Th:Bi ratio in the landfill is 100:1. Since
Bi and Ra are assumed to be present in equivalent concentrations, the Th:Ra
ratios are also assumed to be 100:1. Therefore, the average Th concentration
in the landfill is 9,000 pCi/g.
Assumption #3: By ‘Visually integrating” the total volume of soil that contains
>5 pCi/g Ra and assuming that the average Ra concentration in the material
is 90 pCi/g, the total Ra inventory of the site is 14 Ci Ra. Therefore, the
total Th inventory of the site is 1400 Ci Th.
Assumption #4: Because of the large Th:Ra ratio, future decay of Th to Ra
will cause Ra activity to increase 5-fold over the next 100 years, 9-fold over
the next 200 years, and 35-fold over the next 1,000 years. Therefore, Ra
concentrations will eventually exceed soil criteria for most on-site disposal
options and off-site disposal may be required.
In summary, NRC has assumed, based on indirect measurement methods and conservative
assumptions, that Ra and Th levels are 90 pCi/g and 9,000 pCi/g, respectively, and that the
levels of Ra will eventually exceed acceptable concentrations because Th decay to Ra is not
in equilibrium.
However, a few critical assumptions made by NRC have resulted in gross overestimates of
the amount of Ra and Th present in the landfill. These assumptions may have a significant
impact on the disposal options. These are outlined below.
ciaren
•/aft”
Westlake Landfill
October 29, 1992
Page 3
Issue #1 – Ra Concentrations: A review of the data indicates that the actual
average activity of Ra in all subsurface borings is far less than 90 pCi/g.
Indeed, it is clear that well over half of the samples are at background and
approximately 90% of the samples are far less than 90 pCi/g. The NRC
apparently mistakenly took the arithmetic means of data to derive an average
concentration. However, arithmetic means are appropriate only for data that
are normally distributed. The Ra data at the Site are lognormally distributed,
and therefore, the geometric mean should have been calculated. Lognormal
distributions occur when the bulk of the data are grouped around a certain
value and a small percent of the samples have much higher concentrations
than the rest (outliers). This almost always occurs with “hot spot” data.
Several EPA guidance documents indicate that it is inappropriate to take the
arithmetic mean of data that are not normally distributed.
The impact of taking the arithmetic mean of these data is that the average Ra
concentration throughout the landfill has been overestimated. The geometric
mean, which is a more accurate measure of the central tendency of the data,
is less than 10 pCi/g. Hence, the NRC has overestimated the Ra
concentrations throughout the landfill by almost at least an order of
magnitude.
Issue #2 – Th:Ra Ratios: The 10 surface soil samples contained Th:Ra ratios
ranging from 4:1 to 40:1. However, only 2 ratios were greater than 30:1 and
the mean ratio was approximately 18:1. As with the Ra data, the Th:Ra ratios
are lognormally distributed because there are 1 to 2 “outliers”. Regardless,
NRC essentially ignored these ratios and instead referred to samples taken
off-site at Latty Avenue that were approximately 300:1. NRC arbitrarily
settled on a ratio of 100:1. As noted above, this is 5 times greater than the
true mean of the ratios measured on-site. Hence, NRC’s estimate that
average Th concentrations are 9,000 pCi/g may be at least 50-fold too high.
Issue #3 – Validity of Radiochemical Analyses: An apparent inconsistency
arises in the U:Bi ratios measured in the radiochemical analyses of the surface
soils and those measured by gamma analyses in the subsurface borings. As
is pointed out several times in the Summary Report, U:Ra ratios (and,
therefore, U:Bi ratios) in the subsurface borings are within a very narrow
range, approximately 1:2 to 1:10. However, in the radiochemical analyses of
the surface borings, the U:Bi ratios (and, therefore, the U:Ra ratios) range
c/argn
•/art
Westlake Landfill
October 29, 1992
Page 4
from 2:1 to 1:4,000. This may be indicative of poor data quality in the
radiochemical analyses (e.g., perhaps the instrument was not properly
calibrated). If so, then the thorium data, on which much of NRC’s
assumptions hinge, may not be entirely credible.
Issue #4 – Radiochemical Inventory: The radiochemical inventory for Ra was
estimated by taking the “mean” Ra concentration of 90 pCi/g and multiplying
it by the reported volume of soil that contains > 5 pCi/g Ra. This was done
by “visual integration”. The accuracy of the “visual integration” technique is
unknown. However, if one examines only the Ra data that are >5 pCi/g, the
values are once again lognormally distributed, with a geometric mean of
approximately 10 pCi/g. Hence, the total inventory of Ra at the Site is likely
to be less than 2 Ci, and not 14 Ci as stated in the NRC document. Similarly,
the total Th inventory may very well be 50-fold less than 1400 Ci
(approximately 28 Ci).
Issue #5 – Future Concentrations of Ra in the Landfill: The Summary Report
suggests that Ra concentrations will increase by 5-fold over the next 100 years,
9-fold over the next 200 years, and 35-fold over the next 1,000 years. This
would result in future Ra concentrations that exceed the NRC Branch
Technical Position (BTP) Option 4 of 200 pCi/g. If one assumes a 10 pCi/g
mean Ra concentration and a mean Th:Ra ratio of 18:1, then future Ra
concentrations are: 18 pCi/g in 100 years, 25 pCi/g in 200 years, 72 pCi/g in
1000 years, 161 pCi/g in 5000 years, and a maximum concentration of 186
pCi/g. These values are within Option 4 disposal limits. Accordingly, it is
entirely possible that soil concentrations of Th and Ra in much of the landfill
site will remain within the cleanup targets; only a few isolated “hot spots” may
require specific treatment.
In summary,
• The average Ra concentration and total radioactive inventory has been overestimated
by an order of magnitude.
• The average Th concentration and total radioactive inventory has been overestimated
by 50-fold.
• The radiochemical analyses upon which NRC has developed their estimates of
thorium concentrations may be suspect.
ciaren -im—
Westlake Landfill
October 29, 1992
Page 5
It is entirely possible that a vast majority of the fill can be demonstrated to be within
guidelines now and for hundreds of years into the future.
Thorium Analysis vs. Th:Ra Ratios
The degree of remediation will be driven almost entirely by the established amount of
thorium in the landfill. Accordingly, during future site investigation activities, actual
radiochemical analysis for thorium should be performed, rather than to continue with the
indirect method of estimating thorium levels from radium levels. The elevated Ra currently
in the landfill has not been derived from the elevated levels of Th. The half life of Th is
in the thousands of years, hence, the elevated Ra is primarily due to the enrichment process
or portions of existing Ra being passed along in the ore refining process. In other words
any “ratio” of Th:Ra is strictly an artifact and has no bearing on any real relationship to Thto-
Ra decay segment. Therefore, the focus should be on Th analysis in future
measurements. Once accurate estimates of the Th inventory are established, the future
ingrowth of Ra and simultaneously decay-correct for existing Ra levels can be calculated to
yield a grand total for future Ra concentrations.
Baseline Risk Assessment
EPA will eventually require a baseline risk assessment. ChemRisk has successfully
negotiated with EPA to allow ChemRisk to prepare the baseline assessment on other sites
with full acceptability to EPA. ChemRisk’s experience with radiochemical risk assessments
should give it high credibility with Region VII. Also, few, if any, EPA contractors can match
ChemRisk’s experience in assessing health risks associated with exposure to radioactive
material. At an appropriate stage, ChemRisk is willing, at the request of the PRP’s, to
arrange a meeting with Region VII staff to introduce them to ChemRisk and to demonstrate
ChemRisk’s experience on the issues that must be addressed in performing a radiochemical
risk assessment.
ciaren
~

Post

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

EVALUATION OF THE EPA SELECTED REMEDY FOR OPERABLE UNIT-1 (OU-1)
AT THE WEST LAKE LANDFILL
BRIDGETON, MISSOURI
DATED: 20 July 2016
PREPARED BY:
Robert Alvarez
Senior Scholar
Institute for Policy Studies
Lucas W. Hixson
Director, Field Operations
Environmental Services
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BACKGROUND
In 1973, uranium ore processing residues from the production of nuclear weapons, mixed with contaminated soil from the Latty Avenue Site in Hazelwood, Missouri were transported and illegally dumped in the West Lake Landfill in Bridgeton, Missouri. Currently there are known concentrations of radiologically impacted material (RIM) in areas of the landfill designated by the US Environmental Protection Agency (EPA) as Operable Unit 1 Area 1 and Area 2. The full extent of the contamination relative to the potential impact of an adjacent underground fire* has not yet been determined. However, EPA experts indicate that sufficient data exists to support removal of these materials.
SUMMARY
In 2008, the Environmental Protection Agency (EPA) proposed a Record of Decision (ROD) related to the Operable Unit-1 (OU-1) at the West Lake Landfill (EPA 2008)3. The EPA remedy proposes “in-place” disposal with the installation of a cap/cover over portions of the landfill and long-term monitoring of groundwater at the site.
Internal communications from EPA’s expert reviewers reveal that the proposed remedy is unlikely to protect thousands of urban residents from concentrated radioactive wastes in the floodplain of the Missouri River.
EPA internal analyses find that:
1. The EPA cannot ensure the protectiveness of the cap/cover for toxic uranium processing wastes, in an unlined landfill, that become increasingly radioactive for thousands of years.
2. Radioactive materials attributable to the waste materials at the West Lake Landfill have already been detected in the air, groundwater, surface soils, sediments, and vegetation around the site — at or above regulated standards.
3. An underground fire burning in the wastes in the adjacent Bridgeton Sanitary Landfill compromises the cap/cover remedy by increasing radiological emissions and offsite exposures.
4. The radioactive materials in the landfill can be removed and transported to a licensed radioactive waste landfill without unacceptable risk to the public. However, delays in removal will increase costs and long-term exposures to the public.
*U.S. Fire Administration, Topical Fire Research Series, Landfill Fires, Volume 1, Issue 18 March 2001 (Rev. December 2001)”Spontaneous heating is attributed to 5% of landfill fires. This occurs when underground, decomposing waste rising in temperature combusts as it comes in contact with a methane gas pocket. This is known as a “hotspot…” http://nfa.usfa.dhs.gov/downloads/pdf/statistics/v1i18-508.pdf.
Evaluation of the EPA Selected Remedy for Operable Unit-1 (OU-1) at the West Lake Landfill
This report provides a summary of observations based on internal communications and recommendations provided by Environmental Protection Agency (EPA) experts in documents published by Agency, including technical experts from the EPA Office of Research and Development, Engineering Technical Support Center (ETSC)1 in 2014 and from the EPA National Remedy Review Board (NRRB)2 in 2013- which was withheld from the public until mid-2016.
Evaluation of the EPA Selected Remedy for Operable Unit-1 at the West Lake Landfill 2 | P a g e
FINDINGS
1. The EPA cannot ensure the protectiveness of the cap/cover of toxic uranium processing wastes, in an unlined landfill, that become increasingly radioactive for thousands of years.
a. The EPA’s own experts pointed out the known shortcomings with the proposed remedy design and recommended that Region 7 look into alternative remedies;4
In March 2013, EPA experts from the National Remedy Review Board (NRRB) stated that: “[the proposed remedy] lacked sufficient information on the long-term protectiveness of this alternative.” Furthermore, the NRRB stated: “both of the landfill designs (RCRA Subtitle D and UMTRCA) proposed in the 2008 ROD and 2011 SFS have known shortcomings for handling radioactive waste by itself, let alone handling radioactive waste in a humid region as it would be at the West Lake Landfill.”
The proposed remedy set an unprecedented limit for radiological contamination that was 18 times greater than previously allowed for such wastes located in an urban area.5
The NRRB recommended that instead of enclosing the wastes that Region 7 should excavate the radiological waste and transport it to facilities designed to provide long-term management for such materials.6
The NRRB also determined that the proposed long-term monitoring of the groundwater by itself is not a CERCLA remedy and so could not be a component of the ROD selected remedy.
b. The radiologically-impacted material in the West Lake Landfill is highly toxic and will increase in radioactivity and toxicity over time leading to increased risk to the public;7
The known radiologically-impacted material (RIM) disposed of in the West Lake Landfill is out of secular equilibrium and as daughter products grow back into normal concentrations, the waste materials will increase in radioactivity, toxicity, and risk to the public over time for the at least 10,000 years.
The EPA National Remedy Review Board (NRRB) detailed the dangerous nature of the materials noting, “Based on the package provided to the Board, it appears that there are potentially significant amounts of RIM that are highly toxic (e.g., based on NRC estimates in the 1982 and 1988 reports, radium of up to 22,000 pCi/g, bismuth-214 up to 19,000 pCi/g, and average thorium-230 concentrations of 9,000 pCi/g.” and; “Given the presence of highly radioactive material at this site, and the fact that its hazardous nature will continue to increase over time, the Board believes excavating and/or treatment of any amount of the RIM should lead to important risk reduction.”
The EPA’s cap/cover remedy proposed in the 2008 ROD and 2011 Supplemental Feasibility Study (SFS) does not address the in-growth of radioactivity over time that will occur in the landfill.
3 | P a g e 07/20/2016
c) The EPA’s proposed cap/cover would not protect the groundwater within and beyond around the landfill from becoming contaminated;
The EPA has not demonstrated that the groundwater can be protected from contamination if the cap/cover remedy as proposed in the 2008 ROD and 2011 SFS is approved. Samples of groundwater at the landfill have found levels of contamination that greatly exceed federal permissible maximum contaminant levels (MCLs) and indicate both the off-site migration of groundwater as well as the potential impact on offsite vegetation.8 9 Exceeding an MCL in groundwater would require a response action according to CERCLA protocol.10,11
The West Lake Landfill is an unlined landfill with no engineering barriers12 in the alluvial floodplain waters that flow into the Missouri River, upstream of the confluence with the Mississippi River. Groundwater levels can highly fluctuate according to rainfall event, and river levels can interact directly with surface water and groundwater runoff near the landfill. Because of the lack of engineered protection at the landfill, groundwater at the site can come into contact with RIM material and spread contamination in the highly permeable alluvial aquifer, and into the deeper bedrock aquifer.
It is extremely difficult to clean up contaminated groundwater. Every available corrective action to prevent groundwater contamination by RIM material in the West Lake Landfill should be considered. As long as the radioactive material remains in the landfill, the groundwater will continue to be contaminated.
d) EPA experts have raised serious concerns with the analysis and characterization of the RIM at West Lake;
In 2013, the NRRB raised a number of serious concerns with “…the way the nature and extent of the RIM at the site was characterized….” The Board pointed out that most of the RIM is located at or near the surface of the landfill (within 10 feet of the surface) as opposed to characterizations made in the ROD and SFS that the materials would be difficult to excavate. The lack of cover materials increases risk to members of the public, because there few if any barriers preventing the migration of radioactive materials and gases from the landfill into the air, groundwater and local environment around the facility.13
The EPA Office of Research and Development (ORD) pointed out that the lack of accurate accounting of the radioactive wastes at West Lake increases the uncertainties related to the potential impacts of the underground fire, at the adjacent Bridgeton Landfill.14
e) Alternative remedies could provide a more permanent remedy protective of the public;
The EPA National Remedy Review Board (NRRB) pointed out that the latest technologies could be employed to sort RIM from Non-RIM materials. The radioactive wastes could be then be sent to a dedicated and regulated radioactive disposal facility,
“Given the presence of highly radioactive material at this site, and the fact that its hazardous nature will continue to increase over time, the Board believes excavating and/or treating any amount of the RIM should lead to important risk reduction. Where it appears that much if not all of the RIM is located near the surface, cleanup at this site appears less complicated than other sites….Radiological material is also easily sorted out in the field with portable instruments that provide instantaneous measurements to ensure that only contaminated material is retrieved which, in turn, minimizes disposal costs.”
Evaluation of the EPA Selected Remedy for Operable Unit-1 at the West Lake Landfill 4 | P a g e
2. Radioactive wastes from the West Lake Landfill have already been detected in the air, groundwater, surface soils trees and other vegetation around the site, at levels above federal permissible Maximum Contamination Levels (MCLs).
Uranium, thorium and their related decay products have been detected in off-site vegetation on private properties around the landfill.15
RIM material has migrated beyond the landfill by surface water transport during strong rainfall events.16
Samples of groundwater at and around the landfill have found levels of contamination that exceed standards.17
Measurements of radon in air conducted for the 2011 SFS found concentrations of radon that nearly exceeded UMTRCA standards.
Levels of unsupported lead have been detected in the local environment around the landfill out of equilibrium with background levels of radon and radium.18
3. An underground fire, burning in the adjacent Bridgeton Sanitary Landfill, could seriously compromise the cap/cover remedy by increasing radiological emissions and offsite exposures.
In December 2010, operators of the Bridgeton Sanitary Landfill detected elevated temperatures and carbon monoxide levels indicating an underground fire was burning in an area adjacent to and connected with known contaminated areas of the West Lake Landfill. The movement of the underground fire in the South Quarry has been unpredictable and there are no estimates of the length of time it would take for the underground fire to reach the RIM in Area 1.
The threat of an underground fire reaching the nuclear waste was of such concern that the Potential Responsible Parties (PRPs) contracted a company called Engineering Management Support, Inc. (EMSI) to prepare a report the potential risks that would be generated if the fire were to interact with the RIM materials. The EMSI report was released to the public in January 2014.
On March 28, 2014, at the request of the EPA, a technical review of the EMSI report on the potential impacts of fire was conducted by the Office of Research and Development – who predicted that an underground fire in OU-1 would:
• Create long-term risks to people and the environment;19
• Limit the effectiveness of the proposed remedy in the 2008 ROD and 2011 SFS, even with a proper cap/cover design, inspection and maintenance;2021
• Increase the temperature and pressure conditions within the landfill, generating large amounts of steam and forcing out a larger volume of gases (including radon) and fine particulates into the local environment;22
• Increase production of contaminated leachate and dissolved gases that can migrate into the groundwater;23
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• Increase potential for releases of radon at levels of concern;
i. Measurements of radon around the landfill for the 2011 SFS recorded concentrations close to Uranium Mill Tailings Radiation Control Act (UMTRCA) standards.24
ii. An underground fire in OU-1 would be expected to further reduce the ability of the waste materials to retain radon gas. By reducing the amount of moisture in the buried wastes, thereby increasing the space between soil particles, more radon will escape;25
• A cap/cover installed over impacted areas at the West Lake Landfill could also hinder efforts to monitor and respond to future underground fire events.26
4. The radioactive materials in the landfill can be removed and transported safely to licensed radioactive waste landfill. However, delays in removal will increase costs and long-term exposures to the public.
Downhole gamma logging and laboratory analyses conducted at the West Lake Landfill reveal that the radiologically impacted materials are generally found at depths ranging between the surface and top 6 feet of topsoil. There are also hot spots of contamination could be targeted for excavation and removal.
In February 2012 the EPA’s National Remedy Review Board (NRRB) conducted its review of the EPA’s Region 7 proposal for remedial action of Operable Unit 1 at the West Lake Landfill. In March 2013, the Board finalized its draft discussions, which concluded
“…based on the fact that the Agency has safely cleaned up numerous hazardous waste sites with radiological contamination across the country, including many in residential areas, the cleanup work can be done safely without unacceptable risk…”
The NRRB recommended that EPA Region 7 should:
“…develop an alternative that reflects an approach which surgically removes the RIM, which appears to be a discrete, reachable source term that will continue to increase in toxicity over hundreds and thousands of years…”
Evaluation of the EPA Selected Remedy for Operable Unit-1 at the West Lake Landfill 6 | P a g e
CONCLUSIONS
The EPA has yet to propose a plan for the excavation of highly radioactive materials from the West Lake Landfill, despite their own scientific evidence and recommendations from their own staff experts.
The Federal Government has been removing radiological contaminants from residential and commercial properties for the past seventy years in order to reduce hazards stemming from exposure to members of the public. The removal of radiologically-impacted source material is protective and should be an important objective of any proposed cleanup. These cleanup activities can be safely and efficiently completed with appropriate engineering controls and in accordance with approved health and safety plans.
In the near term, efforts should be made to:
1. Evaluate and implement immediate responses to prevent an underground fire from coming into contact with RIM material;
2. Identify current technologies which could be employed to sort RIM materials;
3. Determine the vertical and linear characterization of groundwater contamination and potential groundwater plume as opposed to isolated groundwater hot-spots;
4. Detect and characterize additional hot spots in the landfill outside of the known contaminated areas;
5. Facilitate the excavation of RIM material from the West Lake Landfill and its shipment and ultimate disposal at a dedicated and licensed disposal facility;
Finally, in accordance with expert evaluations, the proposed remedy in the 2008 ROD should be replaced with a more permanent and protective removal remedy that will reduce hazards to the public. Such a remedy should be developed with feedback from the community.
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ACRONYMS
CERCLA
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
EMSI
Engineering Management Support, Inc.
EPA
Environmental Protection Agency
ETSC
EPA ORD Engineering Technical Support Center
MCL
Maximum Contaminant Level
NRRB
National Remedy Review Board
ORD
EPA Office of Research and Development
OU-1
Operable Unit-1
PRP
Potentially Responsible Party
RCA
Recycled Concrete Aggregate
RIM
Radiologically-Impacted Material
ROD
Record of Decision
SFS
Supplemental Feasibility Study
UMTRCA
Uranium Mill Tailings Radiation Control Act
Evaluation of the EPA Selected Remedy for Operable Unit-1 at the West Lake Landfill 8 | P a g e
ENDNOTES
1 U.S. Environmental Protection Agency, Memorandum, From: John McKernan, ScD, CIH Director, ORD Engineering Technical Support Center (ETSC), To: Dan Gravatt, RPM U.S. EPA Region 7, Subject: Observations on the EMSI report: Evaluation of Possible Impacts of a Potential Subsurface Smoldering Event on the Record of Decision – Selected Remedy for Operable Unit-1 at the West Lake Landfill, Dated January 14, 2014, March 28, 2014. https://semspub.epa.gov/work/07/30284983.pdf
2 U.S. Environmental Protection Agency, National Remedy Review Board Discussions Regarding the Remedy at the West Lake Landfill Superfund Site, February 28, 2013. http://moenvironment.org/files/WestLakeNRRB_MCEnotes.pdf (The National Remedy Review Board (NRRB) is a peer review group created to ensure that proposed Superfund cleanup decisions are consistent with Superfund law, regulations and guidance. NRRB members are EPA managers and senior technical and policy experts with significant experience in Superfund remedy selection issues.)
3 U.S. Environmental Protection Agency, Record of Decision, West Lake Landfill Site, Bridgeton, Missouri, Operable Unit 1, May 2008. http://westlakelandfill.com/Portals/0/Documents/West%20Lake%20ROD%20OU1%20signed%2005-29-08.pdf
4 Comments from NRRB Reviewer John Frisco on PRP Scope of Work: Alternative Cover Designs and Fate and Transport Modelling, “Not sure why an ET [evapotranspiration] Cover is even being considered at this site since its deficiencies have already been identified (Albright and Benson).”
5 Inside EPA, EPA Orders Rare Review of Radioactive Cleanup Plan at Precedential Site, June 28, 2010
6 Internal E-Mail from NRRB Reviewer John Frisco dated February 15th, 2012 stated “Radiological contamination remains active for a very long time and would require long-term management wherever it ends up. For this reason, where possible, we try to send such material to facilities designed specifically for this purpose (e.g., Idaho, Utah). If one could safely and efficiently extract the radiological waste that might be an option worth consideration.”
7 Comments from NRRB Reviewer Charles Openchowski on PRP Scope of Work for groundwater, “The NRC reports also discuss how the toxicity of this RIM will continue to increase over time…this increase in Ra-226 must be considered in evaluating the long-term hazard posed by this radioactive material.” The SFS also acknowledges this fact.”
8 State of Missouri Attorney General’s Office, “Westlake Landfill Tree Core Analysis Report,” Dr. Joel G. Burken, Dr. Shoaib Usman, September 2, 2015 – Scientific data published by the State of Missouri Attorney General’s Office, demonstrated the potential for RIM to transfer offsite. Tree coring analysis conducted around the West Lake Landfill observed elevated radiologic counts of U-238 and U-235 in many of the analyzed samples. These elevated levels indicate offsite migration of RIM into the local environment.
9 Missouri Department of Natural Resources,” Bridgeton Sanitary Landfill Groundwater Investigation Report,” St. Louis County, Missouri, prepared for the Attorney General of Missouri – Analysis of potentiometric contours published by the State of Missouri Attorney General’s Office indicate that groundwater flows in a westerly direction, angling away from the landfill toward the Missouri River.
10 OSWER Directive 9355.0-30, Role of the Baseline Risk Assessment in Superfund Remedy Selection Decisions, April 22nd, 1991
11 OSWER Directive 9283.1-33, Summary of Key Existing EPA CERCLA Policies for Groundwater Restoration
12 Robert E Criss, Risk and Character of Radioactive Waste at the West Lake Landfill, Bridgeton, Missouri, March 14, 2013 – “Specifically, it has no basal clay liner, no plastic sheeting, no internal cells, no leachate collection system, nor any type of protective cap, all of which are standard requirements for modern landfills. Instead the West Lake Landfill is a chaotic pile of debris covered by unmanaged “natural” vegetation, surrounded by a fence with radioactive hazard signs. This landfill is an unsuitable host for any type of radwaste, industrial waste, chemical waste, or even ordinary domestic waste.” http://moenvironment.org/images/West_Lake_Rept03142013.pdf
13 Environmental Protection Agency, West Lake Update – EPA to Conduct Additional Sediment Sampling at the West Lake Landfill, May 26th, 2016 – EPA analysis has determined that RIM materials are being transported off-site with surface water after significant rain events and collecting in sediment around the landfill.
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14 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary Bullet Point #2, “Since we do not have a full accounting of the material in OU-1, we cannot make a definitive assessment regarding the potential for chemical reactions between the RIM and non-RIM materials if an SSE (Sub-Surface Smoldering Event) were to occur. If these reactions were to occur, they could cause a rapid buildup of heat or gas, and subsequent reactions or reactive conditions in the landfill.”
15 State of Missouri Attorney General’s Office, Westlake Landfill Tree Core Analysis Report, Dr. Joel G. Burken, Dr. Shoaib Usman, September 2nd, 2015
16 Environmental Protection Agency, West Lake Update — EPA to Conduct Additional Sediment Sampling at the West Lake Landfill, May 26th, 2016.
17 Internal Comments by Charles O. on PRP Groundwater Scope of Work, “Based on information presented to the [National Remedy Review] Board, it appears that there have been some samples of groundwater at this site that exceed standards considered as ARARs…Generally, under existing Agency guidance, exceeding a maximum contaminant level in groundwater normally would warrant a response action.”
18 M. Kaltofen, R. Alvarez, L. Hixson, Tracking legacy radionuclides in St. Louis, Missouri, via unsupported 210Pb, Journal of Environmental Radioactivity, December 2015. http://www.coldwatercreekfacts.com/media/reports/Alvarez-Journal-2015.pdf
19 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #4, “We do not support the conclusion that no additional long term risks would be created in the event of a SSE at OU-1. There are at least two risk pathways that could exist from an SSE [subsurface smoldering event]. The first is through increased air exposures to contaminants such as radon. As airborne concentrations of radon increase, so would the risk to people. The second pathway is increased leachate production that could move contaminants and dissolved radon gas from OU-1 into the groundwater.”
20 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #2, “…using the higher temperatures observed in the Bridgeton Landfill as a worse-case scenario, these temperatures may cause the structural integrity of the cap called for in the 2008 ROD to be adversely affected. This could potentially include surface cracks and fissures in the cap extending down into the waste material, and potentially cause permeation of the cover used.”
21 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #2, “…if a SSE occurs, short-term risks may be present even with proper cap design, inspection and maintenance.”
22 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary Bullet Point #3, “A SSE in OU-1 would be expected to create increased pressure conditions within the landfill and force out entrained gases, including radon.”
23 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #5, “Short-term effects of an SSE could also include greater amounts of leachate production, which has been observed at the Bridgeton Landfill from condensation of large amounts of steam. An SSE may result in increased emissions of radon and other contaminants in the air and groundwater, even with annual inspections and proper maintenance of designs discussed in the 2008 ROD and 2011 SFS.”
24 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #3, “Given that measurements of radon in air during the SFS were close to a Uranium Mill Tailings Radiation Control Act (UMTRCA) standard, there is potential for radon releases at levels of concern if a SSE occurs in OU-1. This observation does not consider other environmental conditions that could cause radon and other landfill gas concentrations to increase at ground level, such as atmospheric inversions.”
25 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #4, “We do not support the conclusion that no additional long term risks would be created in the event of a SSE at OU-1. There are at least two risk pathways that could exist from a SSE. The first is through increased air exposures to contaminants such as radon. As airborne concentrations of radon increase, so would the risk to people.”
26 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #3, “…a SSE may be present in OU-1 for a long period of time before it is detected, because the only apparent means to detect a SSE after closure is through annual visual inspections.”

Post

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

… .
··•
SUPI’I.Fl-tr.NTAL RErORT
INVESTICATIO:·l FOP. URANilJi’t/DIORlln-2
.
COTTER CORPor”‘TION. J..J\’ITY AVENUE SITf., ST. LOUIS, MISSOUIU
OCTOnER 20, 1976
“Pursuant to the oncoing investigation of possible uranium/thorium
contamination at the Latty Avenue site, Mer.~1~. J. A. Pagliaro and
a. T. Gibson performed a site inspection Oll Octoher 20, 1976. The
pu~~osc of this inspection vas to identify tha property owner from
·county tax records, to surv~y the proparty with bct~-gamma nnd
.alphn survey instrumentation, and to obtain selected soil and
·vegetation samples for laboratory analy~cs.
I
The records revie~oTed at the St. Louis County Building, 41 South
Central.. St. Louis, Missouri, were the current county prop~rty tax
rolls. County parsonnel stated the tax recorcs cxnmined were
dated as of July 1976. The record indicated the followin~:
Address~ 9200 J..atty Avenue
·'””‘wner:
Size:
Commercial Disco:.mt C~rporation
SS East Hom:oe StrcC!t
Chicazo, Illinoi~ 6~601
3.5 acres
._ ….
Telephone communica:ion with IE:III was performed to ascertain
whether the pr_opcrLy had since been transferred. A~dition:tl
information w~s received ubich indicated Co~r. “. D.crcinl Discount
Corporation had tr.:nsfcrred c\-mcrship of the prop~rty in August 1976
to the Bayless Company, 175 Outer Road t-lest, Valley rark, Mitu;ouri.
A site invcstig:ltion was then performed and ~amplcs were obtoineci.
Figure 1 indicat~s the relative position of various buildings,
landmarkr., and loccltions of collected samples. The arc~ in Fi.c;urc 1
encompassin~ the ~bandoncd garace. abandoated warehouse building,
and the abandor.ed and boarded-up burned building w:ts estimated to be
approximatcly”thr.ec ())·acres. The entire area, in~luding the
varebouse area nr:J plowed field, \.”as e~timatcd to be in excess

Post

1978-02-01 – DOE – Summary of Manhattan Project Uranium Flow Sheet

J. L. Livenaan, ASEV
8~ B. Creenleigb, cc
t. G~ Hnlatt, H:latorian ‘a
Office, XS
fEB 1 t978
. .
,.. ·.. . ‘
– –· ~~,:- ~ . ! ·:: :~:-;.
z: • .; … _ . ….. . “” – • ::·
-··.. .
; .· :-:'(. .
Xa our effort• to dnelop a ~late 1de:at1l1cati01l of fol”CCU’lJ.:
devalop the ancloaecl s..-ary of ralaticmah1.pe -.oug the a1tea frora tb.8
.
MID hiatory. The re•iev pray idea a tnterutina perapect~•• a4 ida.ctfi-
the fU11Ctiona of tbe var1oua titea ccma1dered 1D the Pcmaerl7
ft111Ad Mm:J/AE.C Site Survey l’ro&r•·
IDcloaurea
u atated
cc v/o uc.ll A. J. Whi.t:ma:n. ~
bee: V. E. Mot t, ECT
R. Fros t , Aerospace
J j?:~
/sl
VUliam. E. Matt” Director
Dlrisiou of Rnviroum.ental
Caatrol TecbQology
Doe GermantoWJl
Records Ho1dlng Mea
REPOSITORY—:=:EM~S:-::UBJ~J~~FII=~fB~
COLLECTION J08 t~
BOXNO. lzr? ~ Foto’fR ~0 /JJI!.HW~ I
{}wHt;/slit/Ai ,
£Ct. An/N ECT lrJ.R
R~~~~J~~~:~c~a~v——~~~~;t~t~———
01/lB/7 8 01/ ;:.. :}78,
· .:’
!<- •• • .. Memo to the rues THRU: :Robert W. Ramsey, Jr., Assistant Director for Nuclear Programs ·Division of Environmental Control Technology, OOE-HQ DECON'l'AMINA.TION Al'm DECOMMISSIONING: REVIEW OF MANHATTAN DIS'IRICT HIS'IORY ( CIASSll''IED OOCUMENTS) - MED .:.· The subject history is comprised of eight ( 8) books containing J6 volumes which are further di v.Ld.ed into parts am sections. The historr. covers the activities of the Manhattan District frOm prior to its inception on August 16, 1942, untU the. entire project was turned over to the U.s. AEC through the Atomic Energr Act of 19 46 on December 31, 1946. Hr. Robert W. Ramsey, Jr. asked that I review the subject documents to ascertain i! the list of si.tes, previously used (during the Manhattan ..... D1strict activities) for operations involving Uranium ores, oxides, . daughter products or other related radioactive materials, was complete in that no locations associated with the MED were omitted from the previously compiled list o! si.tes. I understood. that the subject documents were not reViemed by those that compiled the original list ?t "~AEC-ERDA Previously Used Sites." To make an indepth review of the MED history would take an undue length· or time and produce much unusable data (in regard to the information required). Therefore, Book I, volume I, which contained general information includ.Ulg a combined tab~e of contents_ (appendix B) was reviewed. · This table of contents was broken down by book, volume, chapter, section, and/or par~graph arn appendices. Also within the table of contents was an introduction to the history which inc~u.des, in paragraph number 1-5, page 1.15, "What tha History Contai.ns." This paragraph gives very briefly (a paragraph to a few pages) a description of the content for the various books and volumes. The comprehensive table of contents was reviewed to determine what 'books would be applicable to, :m::l .furnish the information requested by, Mr .. Ramsey. It appeared from this study that Book VII, Volume 1 and 2, entitled "Feed Material, Special Procurement and Geographical Exploration," 'ht)uld furnish the required. data. In conjtmction with Book VII, Book I, volume 9, was also read. '!1lis volume entitled "Priorities Program" only mentions uranium once when the "Uranium Project" was given the highest priority by President Roosevelt. The volume does mt discuss "feed material" and talks to non-ra.d.ioacti ve materials, re: steel, aluminum, silver, machinery, lumber, etc. Based on the above, attention was focused on the content of Book VII, Volume 1. The ir..formation contained therein contained data relative to .feed r::.aterials and special procurement. Part A wa.s "General Features.'' "Part B-Procurement" dealt with materials from Africa, Canada, and the U.S., Market and !1iscellaneous Procurement., and Pr-ocurement of Other :·11'·, . . . ~- .. . , .·.·.~ lt·; • . I 1 l I i 1 r ! ..~. . ~ . -.··.: ~.·-.-· .. . :· ... ;•. .. · .,.. . ,..,. •· Radi.oacti ve Materials. Part C talked ·to the refining, treatment, sZJd . · . .·., production of the various ores, oxides, metals, Thorium, Quality · -···· Control., and. Accountability. . ·c:·#~~ 'lbe procurement, storage, am processing of the basic raw materials . containing uranium is summed up as follows: •·. ·:·····. -~:-· The ores ard/or oxides received from the African sources -were stored · ·. in various warehouses. These storage areas were: (l) Archer-Daniels-Medlend co. 'Warehouse, Port Richmond, staten Island, NY (prior to the _ , MED); (2) Seneca Ordanance Depot, Romulus, NY}· (3} Clinton ~er· .,!'"-::-, Works, Clinton (Oak Ridge), Tennessee; and (4 Perry Warehouse, Hiddl.esex, NJ. The main storage area was the Perry Warehouse. The. bulk of. the African ores were stored there. This location also became a sampling, weighing, and assaying facility. Inasmuch as the contract · 14th the African source called for only the black oxide, the tailing and residue containing the radium and other precious metals were returned to the verrlor. Those residues from ores conta:i.id.ng greater· than l~ U o8 were stored at the Clinton Engineer Works, Tennessee, ·or at the ~erry Warehouse, Middlesex, NJ, prior to shipment. back to the -vemor. Residues from ores containing less than 1~ tr1o8 were stored at t.he Lake Ontario Ordanance WOrks prior to sh:l.pment to the wmor. Some of the residues were returned to the Belgium f'acility of African Metals, aDd some is still at the U.S. storage sites. The .A.tri.can ores samples were assayed arrl weighed by Lucius Pitken, Hew York City, NY; Ledoux and CO., New York Ci.ty, NY; and Frick Chemical. Laboratory, Princeton University 1 Princetown, NJ. Tbe African ores t-rere refined to black oxides (U10~) at facilities of the Linde Ai.r Products Co.,. Tonawanda, NY; Eldo~do Mining and Refiiii.ng Ltd., Fort Hope, Ontario, Canada; and Vitro Manufacturing Co. , Cannonsburg, PA. The Canadian ores were refined at the Port Hope facility of the Eldorado M1ning and Refinery Ltd. The .American ores (Carnotite) ~:ere processed tor Vanafll.um by U.S. Vanadium Corp. at Uravan, Colorado. The Vanadium sand tailings were also processed at the USV Uravan plant for Uran:i.um Oxide. These went d.irectly to Linde. They (USV) also had a plant at Dur~o, CO, for processing Vanadium tailings and sands to produce a green sluge. The output from the USV Durando and Uravan facilities went to Grand Junctio~, Colorado, for processing to yellow sluge (15% U10g) that in t-.;...-n went to the Linde refinery at Tonawanda, NY. anies and locations noted in flow o£ Uranium ores, tailings,
or slimes to the :finished product have been accounted for in the listing
of “MED-AEC-EliDA Sites Previously Used’f as complied by ECT. There were
;oo companies or organizations ttat could not be accounted for in this
particular phase of the MED history that I reviewed.
_a., a side note, the Thorium obtained for RMl at Iowa State College was
all procured by Lindsay Light and Chemical Co., West Chicago, IL. This
COmpallT i!J also accounted for in the aforementioned listing.
Quality control of various processes in the ore/metal chain tiere done by
University of Chicago, Hetallurgy Lab, Chicago, n.;. Princeton University,
Princeton, NJ; MIT, Cambridge, I-!A; and t..”BS, Washington, DC. All these
organizations are on the aforementioned listings. ) AI .,;) L~
‘- /t[& ,-~~z-:~;~
.kthur ,- • Whitman, Assistant
to the Director
Bioenvironmental Sciences Division
StOIUOl!
All.a4EII- ~IEU-MDL.MD
~:a.. WAREHouse
f’Ofl’f RtolliiOICI• STATEN IS
.——————
ftiGHING-SMIP\.1~ a
A$SAVIftG (SI[ALED SAIIPLI:S
~ MIOCK.nEX-H . .I.)
f’IERRY’ ‘W~(HQUSE
MIOOL£$EX, N.J.
LUCIUS PITKIN
NVC, N.Y.
LI’!DOUX a Co.
fl.'(
~ICIC <:H£1111. LA& f'RINC:n'ON UNIV. f'RINCIEfOM, N.J. VARsoui A£FIJIIMitS ----------------------~ TAILINGS Slt)IWIE P'Oit ,._ _______ ., AI'IIICAN Mf:TALS C.. 4/SV- li!oiR:II $'1af(S -oiiDoW ~ ve"- ~~~ .... ~ ,. ._.,," IIIICW- tMLLI'-CKIIOOT (;~·~~ C. MCW MUIHI.Aitt wew 4otrot1T ILICTIIIOI«t

Post

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

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

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

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

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

\
– 5-
Results ore given in lobi e 7. J n cddi ti on, within each block maxi mum
beta-gamma dose rates were determined. Readings for those blocks where
. the maximum within the block exceeded the ~axirMJm of the four corners
are given in Fig. 11. It is evident from the resutb shown in Table 7 and
Fig. 11 that beta-gamma dose rates at t em above the surface exceed 0.20
mrad/hr outdoors over o significant portion of the property.
Resu I ts .o f S0 1” I Sa mp I e A ro I yses: Co ncentrah•o ns o f 226Ro , 238U , on d 227A c
i.n soi I sampt es coli ected during a presurvey visit and in one samp I e taken
from a surveyor’s work boots are presented in Table 6. 227
Ac is in the
235u
chain and is a daughter of
231
Pa which is known to have been present in
large quantities in some of the residues once stored at the former AEC St.
Louis Airport Storage Site. Strictest NRC limits ·ror ~emitters apply to this
ra d1• 0nucl “• de . 1t appears t ho t sJ• gm·!!n” cant quan t•1t •1 es o f 226Ra , 238U , and 227Ac
ore contained in the soil on the proper!)’, porticli!~dy in the dirt floor in
Po U·I1 d·• ng 1. Be cause no spec:•· r·J C e r~r orts were mao·e to cemove 230rh f rom
pitchblende residue~ stored at the airport site, it must a,e assumed that’ this
radionudide may be present in large quantities. A linited number of samples
will be analyzed for
230
Th. The ~ample whose locotigq is described as “in
.
and aroond BuHdings 1, 2, 3, and 4” was token from ·C surveyor’s boots and
was soil and mud from the area shown in fig. 2. This sample contained t20
pCi
226
Ra/g and 110 pCi
227
Ac/g; the concentration .tJi 230
Th hos not yet
been determined. This sample should be representative of the contamination
beins carried into homes by workers ond visitors on the sfte. •
..
i f
t
t l
1
I • ‘;
.:.:·.·.:.
•__ :
….
~:..
==:;
~
:· • .,!
….. _~
Table 1. Building 1, floor: measurements at grid points of beta-gamma
dose rates and external gamma radiation levels
Grid point Beta-gamma dose r~te External gamma radiation
(Sec Fig. 3) at 1 em level at 1 m
(mrad/hr) {~R/hr)
Al 1.40 320
Bl 2.40 300
Cl 0.35 240
01 1.50 220
El 1.20 190
Fl 1.00 220
Gl 1.30 240
G2 1.00 160
F2 0.60 160
E2 0.40 190
D2 0.30 160
C2 0.30 160
B2 · u.s:> 180
….
“”” ·1.30 220
A3 1..30 240
B3 0.50 220
C3 0. 75 240 ..
D3 0.75 220
E3 0.70 210
F3 o.so 160
G3 o.so 120
C4 0.65 140
..
~
. ···-
~:
~===
:;:;
Table 1. (ccn~’d.)
Grid point
(See Fig. 3)
F4
.E4
D4
C4
84
A4
AS
BS
cs
05
ES
FS
…. ~
…. ¥
G~
F6
E6
D6
C6
86
A6
,,–.
.\ ‘ I
.Builcilng 1. floor: measurements at grid points of beta-gar.m:a·
dose rates and external gamma radiation levels
Beta-gamma dose rate
at I’ em
(mrad/hr)
o.so
0.40
0.35
0.70
0.50
0.20
0.20
0.25
o.so
0.80
0.90
1.00
l.lU
1.60
l.SO
0.90
0.90
1.40
0.65
0.1~
External gawma radiation
level at· 1 m
(lJR/hr)
140
160
160
240
180
120
90
180
210
160
270
190
180
240
240
130
130
160
110
100
..:

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


..:
Building
.. 1
2
3
4
Table 3. Direct measurements of a and B-y contamination levels
on upper walls and ceiling in Buildings 1, 2, 3, and 4
Number of Direct a measurements e-y dose
measurement5 Average Maximum Average
(dpm/lOOcm2 ) (dpm/100c:m2 ) (mr::~d/hr)
67 900 ssoo 0.24
36 280 1144 0.16
-16 so 360 0.07
10 cc. a~cause some radon an~ progeny from previous 2000-
cond intervals remain in the Wrenn chamber, each reading act1.:::1ly rep:::csents a concentr.l’!’:i.C;-,
ich has been intet:;J.·ated over a period of 2 to 4 hr.
: ~· t .. ·–· — . ·-· ·–· -~-….,.—:—–.. ·-………….. -. ______ …. ..
… –·
I ”
::-:-:”:”
·.
Table 6. Concentration of radionuc1ides in soil
samples taken inside and near buildings
Sample
location Depth 226Ra 2380
(pCi/g) (pCi/g)
In and around Buildings
1. 2, 3. and 4 surface 120 N.D. a
Building 2, grid point C3 surface 28 20
Building I. near grid
point 04 6 – 9 in. 240 190
Building 1, near grid
point 04 0 – 6 in. 130 200
Building 2, grid point B2 surface 16 17
Outdoors, near grid
point GlO surface 3 2.1
Outdoors, near grid point
a
JCS • near railro~d spur surfa.ce 2700 N.D.
Building 1. grid point Gl surface 430 860
Building 1. grid point E4 surface 320 550
On railroad spur. near Sh’
~u .. wer of 8uilding 1 surface 470 530
Building l, grid point C3 surface 190 420
Building 1, grid point Al surface 540 1100
aN.D. : not determined.
• : . , ….
.. ..
227Ac
(pCi/g)
110
16
260
140
11
.: 1.3
1300
530
370
390
230
700
.. l
. I
–·
• ~~
-.
~
§=
~-
;=; ;
~– m..
I
,_ \. ··- .
Table 7. Outdoor measurements at grid points of beta-gamma
dose rates and external gamma radiation levels
Grid point Beta-gamma dose rate External gamr.la radiation
(See Fig. ll) at 1 em level at l m
(mrad/hr) (llR/hr)
Al 0.04 20
A2 0.50 125
A3 0.50 220
A4 0.30 220
AS 0.”35 1SS
A6 . 0.20 155
A7 0.18 180
AS 0.18 170
A9 0.25 155
AIO 0.10 80
All 0.10 65
Al2 0.18 110
Al3 . 0.18 140
Al4 1.20 375
A15 0.18 110
Al6 0.13 45
Al7 0.13 45
Al8 0.11 80
Al9 o·.u 80
Bl 0.03
•. 25
..
82 0.08 55
83 0.20 95
– ··-·- – – ____ … _. .. _.. .. –·”•• .
.:
t : . . ·-· ·- ‘ .
table 7. (coat~d.) Outdoor measurements at grid points of beta-gaE~a
dose rates and external_ gamma radiation levels
—-
” M ~.:.:
==
~~
::-::.
!’!” :.:..
=
:y;~ .
-~·· .
:
./ “”. \
‘-•:
Table·,. (cont’d.) Outdoor measurements at grid points of beta-gamma
dose rates and external· gamma radiation levels
Grid point Bet~~amma dose’rate -External_. ga.t-nma radiation
(See Fig. 11) at 1 em level at l rn
(mrad/hr)
.
(llR/hr)
C8 0.08 30
C9 0.09 40
ClO 0.08 45
Cll 0.04 20
Cl2 o.os 25
Cl3 0.04 20
C14 0.03 20
ClS 0.04 25
Cl6. 0.05 20
Cl1 0.23 85
C18 0.21 125
Cl9 0.80 3 ….. f;)
C20 ·0.25 220
Dl 0.05 45
02 0.30 170
03 0.08 45
04 0.08 45
OS 0.10 40
06 0.1·3 ss
D7 0.06 . 45
D8 . 0.08 45
·’ ,” .
.· .. , ..
.. •. •
….. -·
)
I
\ ·.. ·1
. . I
!
.: ….

= ~
:c…·

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

‘ !

• ‘:””-:.:,.
:
~
==·
~
~~;
-~~i
‘ ,
Table 7. (cont’d.) Outdoor measurements at grid points of b~~a-garr~a
dose rates and external. gamma radiation levels
Grid point
{See Fig. ll)
Ell
El2
El3
El4
ElS
El6
E17
El8
E19
E20
Fl
F2
F.3
f4
F5
F6
F7
F8
F9
FlO
Fll
Fl2
Beta-gamma dose rate
at l em
.. : . >
(mrad/hr)
0.03
0.04
0.04
0.08
0.08
0.14
0.06
0.06
0.06
0.55
0.15
0.10
0.10
0.18
0.28
0.08
0.06
0.06
0.10
0.06
0.05
0.06
External ga~”a radiation
level at· 1 m
(JJR/hrj
20
25
30
35
40
85
35
30
45
150
140
45
80
140
95
65
25·
45
50
45
40
40
..

… – — ·- ··–~— -..
_.
i
i
t
t
t
-·~)
—‘ /-·.. .
; .) \ …
Table 7. {cont’d.) Outdoor measurements at grid points of beta-ga~~a
dose rates and external gamma radiation levels
…..
il ·-~·~”!
. . ~
:=.! ..
~
~
~
!..:.~. === :
;;;; -‘l .
.- ‘””;
Table 7. (cont’d.) Outdoor measurements at grid points of beta-garr~a
dose rates and external gamma radiation levels
Grid point Bet~-gamma dose rate External gar..rna radi. ~··:
.:’:~.).’.”
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….. ~
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‘. :.,._. ………….- …’!’·” _… ..:. .·.: ;•’. ._: _;,.·;~.·..·;..:;·..:·._,..· :_.···-,.::….,.; ….;…..·. ~.·;, ..· ~.
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Auome·y Work ·P•o··du· ct·· · ·, . .· .. …..· .. ·. .. · ·· ·.-·~ ··::.. ~ :.: ,t ·:’. ·.~
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Prepared .In Anticipation of ~~n’: . .. :. .. :~. .~ !r:.~·~>:·, ::. .~ ‘
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…… , . ;- ~ ……. .
n.ew”+ n /.;._-.. ~——–=l·:_· 1>====9
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:-.:~·~;; ….. · .. · .. ·
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……….
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···.: :·, …. ..
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D
m
settling
-P-o-n-d·s· _ _
Colorado
Raffinate
– ·· ..
‘ ~·-·-·
….•.
£
·.~ …… . -· . ;”” .
. ….
.!, ‘ .. ., … ·.~~~
… .. .·, – ··… .
.. :
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…. · .• …
l .•f . …;.·_ . :.,.. .
?.~i~t-:., .. •, ·.
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::..:,·.; .
…: .· . …
··-~
~.:…::• .- ••! .. • . ,. …
. . . ···-·· ·-,. .. · ·:.~· · . ~ tT-·.·.”~ .. ttt ¢ .• !4 . .I A.
Litty Avenue
. . .
0.30
Yellow
B~
0.06 o.os
. ……
c 0 06 0 30 0.100 0~0.02 . • . . • .. – 0.03
.· …. .
.. . … • …. -· • • .;.· .
~—-~o.2o 0 03 ·o.o2
0 0.10 • -0.02
0
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o.o<- -- ·'· \ .. . · ....... . ·- .-.. ·.•·:~ . : ~··: . •. -·. .·: .. .... :~ ~:~-~ ~~ . ..: ·- . ~~ ... -~··· r·...-- .:~· ;~~ ......... - ~:·r~- . ·:. . .·: ..... :, . ... · . ; ..... , ... ~,. 0.01 .,#~'" • .• ---· .• '.*· .• o.os 0.15 0.01 0.02 0.02 o.o1 0.02' 0.02 0.100.02 0.01 0.01 0.04 0.15 o. 04 o. 03 o.os RADIATION MONITORING SURVEY 0.04 0.03 0.07 Values of Gross Activity in MR/hr. at approximately three feet above qrade. April 29, 1974 0.1 0.25 ·"' ;. ~.. . .. .. . .. . :: ·. . . : .· ._.. .. . ..•.. 0.03 .. ~ o. 07 :..-: .. ~·7 .. ;. .·,.. 0~ 0 0.40 0.12

Post

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

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

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

1Rules of Practicetc, requires that a copy of ·an application
for a license to receive waste material from other persons
for the purpose of disposal shall be served by the applicant
on the chief executive of the municipality in \>1hich the ·
activity is to be conducted, or if the activity is not to
be conducted within a municipality, then on the chief
executive of the countyo
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11/3/69
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GUIDELINEs· I•~OR DECONT1’J.1IHATION OF FACIT~ITIES Al.JD. EQUIPC-1F.N’l1
PRIOR TO RELEASE I<'OR UNRESTRICTED USE OR TEP.MINATION OF LICENSES FOR BYPRODUCT, SOURCF., OR SPECJAL NUCLEAR !ljA'J.'EHIAL U. s. Atomic Energy Commission Division of Materials Licensing · . Hashingto~, D. C. 2054-5 APRIL 22, 1970 · ,· 0. ~. .. ., ). ·, .· ... # __ . .. 4J.'he instntctions in this guide :in conjunction Hith Tablec I and II spec.i. fy the raclioacti v':i ty and rudia ti on expos u ce rate l im:i ts ,_.hich chould" be tt:>ed in accomplh;hi ng t h-: deconte.mination and survey of
s urfaces of prcmiGes and equipme.nt prior to a.bandonroeht or relea~e
for unrentr).cted use. The l ili’li ts in ‘l’ables I and II do not apply
to premises , equipment, or scrap containing induced r adioactivity
fo-r 1-1hich 1:-hE: racUo1ogical conside:rations pertinent to their use·
may he d.i fferent. ‘.l’he release of such facilities or items from ·
regulatory control Hill be considered on a case-by-case basis .
1. The licensee shall make e. r easonable effort to eliminate
. retiidu3l. contamins.tion.
2. Radioacti.vi ty on equipment or surfaces shall not be covered
by paint, platinB, or other covering mat eri al unless contumination
J.eve.ls, as detemtined by a survey and documented:
··are belo,·t t he limits spccifieq. i n Tables I or ·II prior to
applying the covering. A r easonable effort must be made to
minimize the contamination p.r.ior to use of any covel.·ing.
3. The. r adioactivity on· the interj.or surfaces of pipes, drain
lines, or duchrork shall be determined by making measurements
at aD. trapi’;; anc1 oth~r a.pp~;·..opri ~.te access pcir!te; provided.
that contamination at these l ocations is .-likely to be representative
of contaminatton on t he interio~ of t he pipes, drain
lines, or ductr,.rork . Surfaces of premises ; equipment, or Gcrap
vrhich a:ce likely to be contaminated but are of such size,
conot’ruction, or location D.s to make the surf’ace inaccessible
.. for purposes of measurement shall be presumed to be contandna.ted
in excess of the liut.i. ts.
.. . .. …
l~. Upon request) the Commission ro.ay authorize a licensee_ to relinquish
possession or control o:f:’ premises, equipment, or scrap having
surfaces conta!crim{ted \-lith ·ma.teriaJ.s in excetis of the l inli ts
specif i ed. ~li s may include, but would not be l imited to) special
circums tances such as raz ine of buildings, transfer of premise:>
to anot her organization conttnuing ‘vork \lith radioactive materials,
or conversion of facilities to a. long-term s~orage or standby
status. Such requests must:
a. Provide detailed, specific information describing the premises,
equipment or scrap, radioac tive c;ontamtna.ntsJ and the nature,
extent) nncl degl.’ee of residual surface contominati o~j(_H~~ /\ \tCH(V;?.’<' b. Provide a detailed healt h and saf ety analys i s \-lhich _reflects that the residual amounts of matcriel.s en· surface areas, together vTitb other considerations such as prosp_ective use of the premises, equi.pment or scrap, are Wllikcly to result · in an tmreasonable risk· to the health and safety of-the public . - 2 5~ ·Prior to release of premises for unrestricted use, the licensee shall make a comprehensive radiat:~,_in survey whi.ch establishes that contamination is -vri.thin the limits specified in Tables I or II. A copy of' the survey report shall be filed \vith the DirectorJ Division of · .,_. MatcTi.a.ls Licensing: US.Al!:c/;..;.'~·.~-shington, D. C. 2051~5, and also the . · ·<"YH1'ector of the Regional.'Di·.vision of Compliance Office having - ·jurisdiction. The report should be filed at least 30 days prior to the planned date of abandor~ent. The survey r~port shall: a. Identif.y the prcnuses. b. Sholf that reasonable effort has been made to eliminate residual contamination. c. Describe the scq~e of.the survey and general procedures followed. d. State the ~indings of the survey in units specified in the instruction. t) rr. ~' ~·~~ /\J~J .. ; .~:.t .t. \' tr~~~:·~ li'ollo-:rh-232, and . 5,000 2 dp~ ojlOO em .1,000 dpm a./100 ct:l.
associat ed decay products – i ‘M.a.ximt!to I 25,000 G.pm JlOO 2
: em
Other isotopes ‘tvhich decay 1,000 d:pm o/100
2
em 100 dpm a./100 em 2 ·Average ( 6) 2 by alpha eoission or by : 500 dpt’l o/100 em 100 .. dpm r:x/100
spontaneous fission ::” I Maximu:o
dp:n · ·wloo· f_m2– .. ., .;.~. 2,500
I · ~ … ;. ;.,: ., :;I cm(5) 2 Av~rage (6) Beta- ga.mma emitters (iso- ,., . 0 . 4 mrad/hr at 1 . 1,000 dpm ry/100 em . (5) 2 topes “tdth decay modes :•··· 0. 2 tlr ad /h.: ~·t lcm 1,000 dpm ~-y/100 ,:~ ‘
other tha:1 alpha e:c.issi on .~. .·. – . Ha:ximum or spontaneous fission) r … ~ 1 .0 mrad/hr a t cm(S) ,
…. !:, .J..
•, .•. . • .
. . fl> .•
(1) E i~her Table I or ‘table II may be used . For e…-ca:cple, if all beta-gamma r eadings were less than 0.4 mrad/hr a t 1 em,
Tab~e I could be used; but if the maximum reading were 0.8 mrad/hr, mat e=ial could be released under Table II provid~
ng·the average was less· than 0 .2 mrad/hr.
(2) t~er e surface contamination by both alpha and beta- gamma emitting .isotopes exists, the limits established for alpha
and beta-ga.n:.ma emitting isotopes shall epply independently.
·,
(3) As – • . “· ‘•f•t
~
;
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.- .,, .. . _.,. -~! .
Mr. Edwar d J. Mc Gra t h .. : I
260 East Jefferson Street
Rockville , Naryland 20850
…….. ~
~ ‘
… …….. . ”• ····· ,. :•· ········ :- -,, . ~
Dear Mr. Mc Gr a t h :
t . • •••••• ·:· . …. .. •’ ””;l!<::~ ~. ~ .. ··~· ·····:·~·.! .- , .... ·· ··· ·-~ .... -. . : ' ! •' •': ,: • ••• ~· . ... ~ • ••• , '·:--· ... .... ... ~! Thank you f o r y.o ~ r l e t t er of June 29, 197.1. I beli eve you are now in d irect cont a c t wi th the proper organizations· within the Atomic Energy Commi ssion to provi de an~:n,,crs t o your. ques t ions rela t ed to d ispos a l of r adioac t ive wa s te ma t e r ial s own ed by the Cot t e r Corpo~ation . The question of burics.l of the materi 20850.
June 29, 1971
The Honorable ~fj,lfrid E. Johnson
. U.S. Atomic Energy Comm1ss’ion
Washington, D.C. 20545
..
Re·: Cotter Corp_Q}:”ation- Radioactive vlastc Disposal Prooosal
Dear Commissj.oner Johnson:
..;
I Pursuant to .your suggestion made during ou.r’ conference
on Ju~e 24, 1971, I am enclos1.ng copies of the corresponde:t..ce
between Cotter Corporation and the Co~~ is sion relati ng to the
disposal of radioactive waste materials owned by the corporation,
‘·rhich are novr located :i.n Haze1wood, Mj.ssouri. · ·
I am also enclosing copies of a preliminary propo~al for
on site burial prepared for Cotter Corporation by the engineering
firm~· of Ryckman, Edgerl cy, Tomlinson and Associates., In c.~
together \ Missouri. W~ will
furnj.sh you with copies of further submissions. and correspondence.·
· · On behalf of Mr. Marcott> Cotter d~rporat ion, and myself,
I wish to thank you for providing us with an opportunity to
discuss with you the problems and public p6licy i ssues which
surround our efforts to dispose of the waste materials safely
and quick4.y.
EJM/dl
G cr.c1~~ l ;.~n! le.;::~r·
United 8~~~eA ~to~ic
Ener£;s· Co;.~r.1 1::;s1~o n
\’!~sh~.n r.:t on D. C. ~05115
Re: CottcP Corpornt1on
\·Taste Dtsposal Projcot
Dea14j !·it’ . ~·~c1J.. “J.:~.~l~:~rr;.fo:rth: ,
;
:~:~~~r.yJ. u.no~1. tho facts ?..nd c~L:t•ct~l:!~ tances herc1nD.f’tcl”‘ set· fol”‘th.
Co~i;0.J.’ Co-rporat-ion hereby m.::tlwa a~)pJ.lc::tt.ton fo:.., a u.tho_rity to dis-.
po:30 or rad:1.oac t:,. ve. \’111~ te ~:;.~ t0.r>io:l at ·’l.on, :tn 1967, purchaned frnm e. pr>lv~te concern
a substnnt1Ql ~uant1ty of ~adiouctlve residues storod .et that time
at. the so cal:tot”l · “n h 1 port rd. te11 in St . Louis, ~·fifHlOUl’l for the pttr~
.-.!J on. ;L,’~. of~'”-‘ ‘-“‘”r_’:”;l”.J’..”._’ “‘0C”””””<''' s .4.1. r'tcr:,.:, t'n,;~:,V~- P•O ""~' ti.J.O. ".',~.. of 1l's.h r~.; tn..:.G :\.'t.·'r".'->‘)•-•’ “1.,,~..1_ ·~·•’1’1 ‘..1…. — “l1′ \•lL•\n.. .n..” 1 (r’…;.rJ otn;; .n’-
abJ.e to t:-.•catment in tho urcm1um n~tll or Cottc!’ Cor>porn’.;ion locutea
in Canon City~ Colo~ado .
‘i’he l”‘en1.dues pnrc:1a0e:1 ucrc ·the P!’Oduct of ~~.rlier Commission
on:·:<:--6.t ions, ~n~ rc pre~en-Gcc1 u. vubstant1al problem ~ t the t.ime \·rhcn th~y \'iCre P.cqn:lrcd by co~~tcr Co:•pm?nt:lon) hcca.use t:he f:J.rm \•lhich pu.rchascd them f'x'CP:1 the Commiss·icn Emd fi>om uhich Cot~t er Corpo:;”)nt:.
1.on ecq,,t:lr>s::H.1 thor: ~~::1 (1 ~one oo speculatively, . .,._:ithout ;:. progr e.n(1 t’uboequ.cntlv tcrm~umted its business -act:l v-
-.iti0t.
!nc1n·:.1et!.tion has
tr c:·.~l3 0Q:,”‘t0d ancl proccnned ~11 of’ the ”!<1. s te r:tate~r:i.eJ. · . \'7h5.ch Has a!~U~1~i.!ble to treatr.:en·;; and made arrano~mGnts for- disp.o"oiti~n of ~ lar>ge quant:t ty of unu~abl e loose r.taterial. ·uon .6 \J.C UJ.VJi:.;J
Thor.e re:::!:lil1S for c:1Cfl03ition ~PPl;O:dr:w.tcly one thoustmd
(1~000) drurn3 f’11lensh, that ~.~ 5.tems snch
as brj.cks > clot ‘I i. n’:”·, ho0tg l gloves. ~r~d t~~(~ 11 i;·:’. ‘.::’he c:!’UQ!S nr•0
Q \~~,~·o P.!; 1._~, 1. :· -~ :\ ~ ;• ;~ r\ ~ H~H:~ l wood_, ~-!:! n n:)’.1t’ 1 •
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Cottc:r’ Corporat. ion J if’ au. thor lzed by th~ Commission to do 80 I
‘·Till t ranspor\: tho. dru:ns .bY truck from HLH~ehYoocl; H:l.noouri to the
qun~ry· o1te at Weldon Spring (a dis\:ance of approximateiy thirt~
(30) m:lleo) o.n(1 dcpon:Vc thm:1 in the quo.l’ry, subject to Couunlsaion
nimD.ar contaminated material; that no conflict
e;dG~~::l :!n this Gituat1o.n \·t:l:’~h the Com.lni.ssion policy against engag:
tnb ~:…;: op·~l’at:ions competitive wj.th p1.~:1.vaJ~ e .tnctustry, s1.ncc exletint:;
p:..•ivatcly oper-ated Haste · dispos~.l fac5.lities ape not clee:l;.gned
in capacity or othcrwine for disposition 6f material in the ~an- ·
t :tty and for·m invol vcd in thie !’>:L tuntion; th:.J.t tho <:lintanco to· t:he ncarGnt comr:l0j."'cJ.uJ. disposal nite, even 1·1cre i.t capable of handlinE; th0 materi~l is t·,·~o hundre(l ( 200) mil e ~ .as opposed to e. cU.st2.nce ·of thii.'t;'l (30) ni.l"Cs fi,om Ha~eh10od to Holdon Spr:tnG, ane othc.riunds or depressions. ·
It is the desire of Cotter Corporatioi1 to reutrn to its Lessor· la~d \•thich
\·till in no vmy he limited in its usefulness or va1ue and \·Jill in no way
endanger the sm-rounding environment and its inhabitants.
1″} {) L~~ t\ .r~~. (· ~· 1.·. r ·~ \f D):.~i
RETA-780
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l . , … ~f t\ ” f t l < ili'······' ) e., .f ' " ' I ~ ' , · · . ·coTTER CORPORATION LATTY AVENLIF. STORI\GF. ·SITE \t!J\ZLE~·IOOu, t4ISSOURI · '-' UNITED ST/,T.ES ATOMIC ENERGY COMMISSION VIASIIINGTON, D.C. 205<1S !·lr. Ed·,Jard .T. NcCrath 260 East Jefferson Street RnckviJ.J.e, ~laryl.'ll.H'I 20fl50 D~ar Mr. McGrath: MAY 2 4 1971 JQJECJEKVED MAY 231971 _·E. J. l\1cGRATH ' This is in r esponse to your l etter of April 28, 1971, proposing to di~pose of cer t ain r adioactive ·Hastes mmed by the Cotter Corporation in an AEC-oHncd quarry at Helclon Spring, Hi ssouri. Your letter sta tes, in_.part; t hn … ”
This s l:atemcnt rai ses some questions on t..rh i ch ”-‘e ~vould apprec:i.a te
ftlt’thcr in~ormation . First, Hhat :i.s the intent of t he phraGe
” or othcn·ris c=’? ~ · Does it mean that the licensed burial ground
operators couJ.d not handle the material ~dthin the safety require-
. ments of their present licenses? Second, i s t he judgment cxpress~d
in this· statement tha t of the Cotter COl.·poration or that of the
licens ed burial ~t”ound o perators? Nore spe cifica lly, h~.v e the three
l i cens ed burial ground ~~crate rs (Nuclear Engineeringj Nu clear Fu~l
Services , nnd Chem-Nucl<:'\.:lr Services) s tated that they could not handle the material? fve twuld apprecia te your vieHs on these points in order to consider the proposal further . 1)0E Sincerely, i~oq~~:~ Divi sion of Haste and Scrap Hanagement ....... ... .... . ~. \ .. . · .. 'l y;. • .... • • l••t. . ~ . . . . .. · ,_~::. ~:.:...~;...:_ .... .:....~~· .. .:.~ ...,.;..,_, .... -: ...... ~~. .... __ _,,,· , . - ·.. ~- -·. ·. ....... . _.. ..... ,; ... ·- ..... ., . ·. o _ ..,., _.., ' •••. : ' .. : ... ,:· ,.r : .-· , ,_o - ~·, ,.•:~_, , 11 ,':.:..,.,-u...-;._.;.'i - .• .-~.,_.,..: ... ,, .,.,·.~&. •~ :_· • ~•a • • •• •-· 0. . -· I I UNITED STATES ATOM !C ENERGY COMM lSSION WASHINGTON, D.C. 20S4S June 2S, 1971 HENORi\NDU£.1 FOR THE r'J.LES SUBJECT: NEE'f!NG \HTH RBPRESEN'l'Ni'IVES OF COTTER CORPORATION At the request of Senator Peter Dominick (Colorado) , · Commission e~ Johnson me t t.o~ith David Harcott, Executive Vice President, ~nd Edward McGrath, Washington Counsel, . fo r Cotter Corporation on June 24, 1971. Others attending were Dr. Martin Biles and u. M. StaebJ.er. 14essrs. Narcott and HcGrath had previously met \'lith personnel from the Divis ion of Haterials Licensing and l'fast.e and Scrap ~1anageme_nt . Cotter Corporation acquired r adioactive r e~idues from early 1\EC milling operations \•lhich had been moved from the St.· Louis Airport to Hazcl\,•ood 1 a site in metropolitan St. Louis, by a Ba ltimore Corporation Hhich Hent bankrupt. The material \·/as acquired from Commercial Di scount 1 the fin.~ncer. of the ori,gj.n~J. _ p,urc.l·~~.s.e. from the AE.C . Selected materials were sent to a plan t at Canyon City for recovery of valuable ~ine ra ls. Cotter has about 15,000 tons of materials to be disposed of in addition to about a thbus~nd drums of contaminated materials which can be disposed of. comme rcially at a reasonable cost. They are COillffiitted to restore the property on \·;hich the material is stored but have found that disposal on-sit~ is not acceptabl~ under present··:r;egulations. The $150, 000 they had ·a llow<::d for on-site disposal is to be compared \vi th an estimate of $2 million they have received from Nuclear Engineering for commercial disposal at a site about 200 miles a\vay. Mr. -Marcott \•Tould like to dispose of t tie material at the quarry formerly used by the AEC near the St. Louis operat~ons ~1hich is about -30 miles from · the Hazelwood site. Dr.' Biles revie\'/Cd the situation at the quarry , .concluding that disposal there would not be accept~ble. The ' basis for the estimate of $2 million for disposal · by Nuclear Engineering was not known but it did not seem consistent: l,vith -the usual charge or aboLtt. $0 . 7o .per cu. ft. for conuuercial disposal plus transportation. (Separate information indicates this estimat~ may incl ude decontamination of buildings at the site.) Dr. Biles suggested that· transporting the materi·al to Colorado 1.. { , v ,, r· r >; n ~~ ~-~~:~·-~
) … … ~ .1. :t :\ ,i. ~.~· . … , .S. !;, •..-. .. J • •• r.
.. . \ ..
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. ·.
a nd adding it to e ~ is ti ng piles of tailings there might
be wor t h exploring since t he mate~ia l i s s imila r and
w~uld be quite small in quantity relative t o these pi l es.
It was agreed that:
a) Both Cotter and AEC (Biles ) would look into
the feasibility of di ~po sa l on other tailings
piles (~ncluding lice ns i ng) . ·
b) Cotter \>IOuld provide a brea’kdO\•Tn of the $2
million estimate from Nuc l ear Engineering .
c)
d)
AEC (Biles) would investiga ~e the basis being
used f9r private conune r c i a l disposal —
in particular whether pricing on a unit volume
basis ·,·las reasonabl e for t his kind of material.
Cotter \·lou l d pr ovi de a summary o f t he history
of t he materia l a nd t he contract obl .:Lga t,?.ons
r e l a t ive t o ul timate disposal associated \·1ith
the va ~ i o u s trans fers .
. “2f, )r] .• ~{;–:;-:<.t 1:~/;,./ U. M. Staebler , · cc: General· Nanager ......... ... .... ---.-" ... ·- Dr. Martin Biles, OS . ~. O'Neill, Cong. Rel. H. NoHak, \vSM C. H~nderson, DR .. · \ \ • ····- "· .... . •.· .• ·. r' •• - - · ; ,\_ •.. /'.· Reference is made to the June 28, ·1971 , fi 1 e memorandum from U ~ M. S taeb 1 er, concerning a meeting with Cotter Corporatjon representatives to discuss the disposal of their residues located in the St. Louis· area. The Cotter Corporation apparently proposed disposing of their residues in the Weldon Spring quarry. We can understand some reluctance to place these materials in the quarry, since the ground \'Jatet' situation in that area is not fully d.efined and "control" could, therefore, be questioned. Two points seem w·orthy of mention in this regard. · First, the dumping of the Cotter residues in either the quarry or the pits at ~leldon, Spring would represent an -exception to the radioa~tive waste burial policy as reflected 1n AEC 180/23. The possibility of establishing a troublesome. precedent should therefore ·be recognized. Second, - the negotiated sales . a9reement with Cotter stated the intent of the agreement to be the relllOVal of all residues, and specific effort \'las made to prevent a "creaming" of the material. Remova 1 from the Hazelwood site was therefore a recognized responsibility .of Cotter•s. --~-------------~~-~ ~ ._ ___ . , _ _ ...... ..... ..;.;..-._., __ ••.. .• ,\,' -i If Headquarters determinest however, that disposing of the Cotter residues_ at Weldon Spring should be approved, we believe that there is a much more acceptable alternative in the Weldon Spring area other than the quarry. The AEC-controlled raffina'te pits at the Weldon Spring site are excellently contained and isolated from the -environment. The Cotter residues are quite similar to what is a1r·eady contained in the pits and represent perhaps a · 10% addition to what is already there. There is .already about.,~ ~illiOB cubic feet of material in the pits, and the Cotter residues woul.:i 1 I ‘·!C t:i n:r 31
/ (~ it..H’. ‘”] ., , ‘ ‘ “”!II
… …. “” .. ….. … … .. … !
Martin B. Biles – 2 – July 14, 1971
be dumped directly into Pit 4, than to transport them across country. AEC
could conceivably negotiate a charge to Cotter for disposal in the pits,
based either upon current commercial rates, or upon our cost of 11directing11
the operation at our end, plus some crudely estimated cost for later
stabilizing the residues. .
We would be pleased to assist further in this matter if requested. As you
are a\’/are, the Genera 1 Manager would have to approve acceptance of offs i te
radioactive wastes at an AEC facility.
OS:JAL
cc: J. A. Erle\’line, AGMO, HQ
F. P. Baranowski, P, HQ
H. A. NOI’Iak, Wm, HQ
‘~s. R. Sapirie
Manager
Oak Ridge Operations
… , ·.:·· \::
UNITED STATES
ATOMIC ENERGY COiv1M lSS!ON
WASHINGTON. o.c. ~O!:i45
Mr.· Edward J. McGrath
260.East Jefferson Stree t
Rockville1 · Maryland 20850
Dear ~JX. McGrath:
.July 22 1 1971
: . .. …. – . – — – .
~hank _ ybu for your lett~~ of June 29, 1971. I believe
you a.re nmv in dir ect contact with the proper organi ?.a·tions
Hithl n the Atomic Energy Commission t o provid~ ans\’lers to
your questions re ~ at e d t o ~isposal o f radioactive waste
mate rials Ot.vned by ·the Cotter Corporati on.
The question of· burial of the material at th e . Haz ~ lwood,
M-issouri·, -site or any other prope rty .c on.troll.cd by Cotter
Corporation should be pursued _,..;ith ·the Divis ion of ~at e ri al s
tic~ nsi ng. Any. questions you may have r e gar ding -burial of
these materials on AEC s ite s s hould be addressed to t he
Divisi011 of Waste and Scrap Manag~en t.
Should there be any f u rther que st.ions, these t\·m Divisions
will either be abl e to answer them or will ens ure that other
appropriate Divisions· \v.i,ll ans~vet~ them f or you.
Sincerely,
(;
w:¥~7′ Comm1.ssioner ·
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..~. ·:. ~ :~.:. I .. , 1,:·: (. “” • .:.) f ‘:< .-. .. ~ I. • ~ ... ..... ........ UNITED STATES ATOMIC ENERGY COMMISSION MEMORANDUI-1 'FOR THE WASHINGTON. D.C. 20545 June 28,·7 FILES ---~· SUBJECT: ' MEETING WITH REPRESENTATIVES OF COTTER CORPORATION At the request of Senator Peter Domi nick (Colorado) , Commissioner Johnson met with David Marcott, Executive Vice President, and Edv1ard McGrath, Washington Couns ~ l, for Cotter Corporation on Ju'ne 24, 1971 . Others . attending \vere Dr . Hartin Biles and U. M~ Staebler. Messrs. Narcott and McGrath had previously met with personnel from the Division of Materials Licensing and Waste and Scrap Management. Cotte~ Corporation acquired radioactive residues from early AEC milling operations \vhich had . been moved· from the St. Louis Airport to Hazeh!Ood, a site in metrop9li tan · St. Louis, by a Baltimore Co~poration which · w~nt bankru~t. · The material \'las acquired fr~:>n\ Connnercial Dis.co~nt I the
.financer of t:he original purch.ase f.r.om the AEC. Selected
materials ‘Vlere sent to a plant at Canyon City fo·r -recovery
of valuable minerals. Cotter has about 15,000 tons of
materials to be disposed of in addition to about a thousand
drums of contamirHited materials which · can be disposed of
con~ercially at a reasonable cost. They arc committed
to restore the property on which the material is stored
but have found that disposal on-site is not acce,ptable
under present regulations. · ·rhe $150 , 000 they’ had allowed
for on-sit~ disposal is to be compared with an estimate
of $2 million they have received from Nuclear F.nginoering
for commercial disposal at a site about 200 miles away.
Mr. Marcott t,o;ould like to dispose of the material at the
quarry formerly used by the ·AEC near the St. Louis.
operations \•lhich is about -30 miles from the Hazelwood
site. Dr. Biles reviewed the situati on ~t . thc_quarry 1
concluding that disposal there would not be ~c·ceptable.
The basis for the estimate of $2 million for di spo~al
by Nuclear:: Engineering \’las not knovm but it did not
seem consistet?-t \ • … ” :~ • ·1.~. ‘\, \
; .
”2J, ) 71, .467-X-t.evv
U, M. St aebler·
· 6c: Ge ne~al Manager
Dr . Martin Bil e s , OS
R. O’Neill , Cong. Rel .
H • Nowak , Y.1SM
C. H~nders on, DR
H. Ililc~
E .. ·l60
f<. Fatllkne:r P-1120 . il. ROWi!X G-117 C. Ue.t\tku:aon J~..ttn~ R. Cunninqharo OS:lS 58.94 7/14 respon.s~ .. LAW OFFICES EDWARD J. McGRATH 280 EAST J EF"FE:RSON STREET RocKVILLE, Z.!;. RYt.AND 20850 130 11 4:> ~- 470 7
June 29, 197f
I
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The Honorable Wilfri d E. Johnson
U.S . Atomic Energy Conunission
Washington, D.C. 20545
Re·: Cotter Corporation- Radioactive vlaste Disposal Propo’sal
Dear Commissioner Johnson :
Pursuant to your suggestion made during our conference
on June 24, 1971 , I am enclosing coptes of· the correspondence
between Cotter Corporation and the Commission relating to the
disposal of radioactive vraste materials ovmed by the corporation,
v1hich are nm’l locat~d in HazehTOod, Missouri. ·
I am also enclosing copies of a preliminary proposal for
on site burial prepared for Cotter Corporation by. the engineering
firmoof Ryckman, Edgerley, Tomlinson and Asso~iates, Inc., ·
together 1’li th a copy of a memorandum by .Mr, · l•larren Goff, Safety
Engineer for Cotter Corporation, reporting -on the conference
betvreen representa~ives of Cotter Corporation and Nuclear
Engineering Company, during which the latter firm gave an
estimate of $2,000,000.00 for burial Of the \’Taste material at
the site owned by that firm in Illinois .
As Mr. ~1arcott advised, ‘I’Te are preparing to submit more
detailed lnformation to the Commission on the proposal for
burial at the present site i n HazehTOod, Missouri. \tfe will
furnish you with ·copies of further submissions and correspondence.
On behalf of Mr. Marcott, Cotter Corporation , and myself,
I wish to thank you for providing us with an opportunity to
discuss with you the problems and public policy issues t’lhich
surround our efforts to dispose of the waste mater1als safely
and quickly.
EJM/dkb
Enclosures
;z_::;rz ·-
Edward J. · ~ath Attorney for Cotter Corporation
– •• – . ::. .._. . t •• • . • • ..
LAW O FFICES
EDWARD J. McGRATH
260 I::A5T JEF F ERSON STREET
RocnV!LLE, HAn\’l.AND 2oaso
-·-
( 3 0 11 424-.. 707 –
!’ – “)
~
·. · ·April 2~, 1971
Jt.r. itobert E. Holl:tngm·rorth,
GGncrn l r-1anag0r’
United St aten At omic
Ener~y Commission
. lt.’a sh1ngton D.C. 205IJ5 ·
· : .
·: · … …. ….
. . .
Cotter- Corporation
Waste Disposal Project
– ·-

·.
..
n~u~0<:1. upon tho facts a.nd c:trcums tnnce6 hereinafter set forth. Cotter Corporation hereby make~ application for author!ty. to d:tspo: 1e o f radloactiv~ 1·1aste matel .. inl de scribed belo\'1 'by depositing th ~ s.~mP. in the abandoned quart•y _ ut1.11zcd f.or eueh dtsposal on the property owned· and controlled by the . Atomic Energy Gommissi.on at ~·feldon Sp~ing~ Ntsaouri. Cotter Gorpor>at.ton, :tn 1967, ·purchased !’r0m a private .e.oncern ·
a substantial quo.nt 1ty of radioactive residues stored ·at · that time
at the ao called “airport site” 1n St. r~ouis, Misaoul’i for the pur- ·
pos e: of’ reproces sin.g that portion of the material wbich ~rns smenaolc
to treatment ‘in the ut”an1um mill· of: Cotter Corporation looatcd
ln Canon City, Colorado. · · .- – ·_ ,. ,·_
. – . . . .
The residues· ·purchased l-lere the product of earlier Commission
oper>a.t1ons, and represented a euhata.ntial problem at the time· when
they Nere acquired by Cotter Corporation; becauee the flrm which
purchneed them from the Commission and f”rom tth1ch Cotter Corpor- ·. –
· o.tion ~cqu1rec1 them had done ao speculatively, ‘<~Ti~hout ·e. program · f~r d1Gpoa1t1on, and subsequently terminated 1ts business act1v- -: it1ea. · ·· · · ' • . ,. ~ Incltt\.le. 1.rhc drums . are . :. _·
· Q\JXrentJs ~ or.~t :~~.\ f.\ t. lh’\nelt~oocl” – ~1issonr1. · ..
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Cotter Corporation, if autho~ized by the Commission to do so,
will transpo~t the drums by truck from Hazelwood, M1saour1 to the
qunrvy site at Noldon Spring (a distance or approximately thirty
{30) miles) and deposit them 1n the quarry, · aubjeot to Commission .
advice and direction, and at the expense of the corporation.
\ve believe deposit in th~ quarr’y’ to be the most sastiaractory
rc3olutiou or all substantial problems· involved in disposition of
the contarn1.nnten material. Among ·the factors \fhich dictate our
conclusion e.re ‘that the quarry site 1a utilized by the Commission
for. (1isposal of ~3 im:tlar contaminated material; -that no ~onflict
e;::tstrJ :ln this nituation ,,,ith the Comm1ae19n policy · aga~nst engag:
tn~ 1.n ope!’at:ions competitive \’lith private industry, since ~xist- ·
inF.; pl’ivately operated. ~oraste disposal ~ac111t1es are not · dee.lgned
in capacity oP other\lliae for disposition of material in -. the ~;\.iantity
and form involved in thia situation; that the distance to the
nearest comme:..–c :to.l disposal site, even \-‘Jere lt capable or handling
the material is two hundred (200) -miles as opposed to a · diatance
or thirty (30) miles from Hazelwood to \’Teldon Spring, and finally.
· the very sttbstantial difference in expense in dinpoaal other . than
at Weldon Spring quarry, even if ·such alternatives were otherwise
feaetb~.e. ·
vic request. the opportunity to present and discuss · thia prQ..:.
posal •tiith you and \’lith those of the Commiss:ton staff.’ . . concerned
\.
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‘I
P R 0 P 0 S A L
for
Df.CONTAMINJ\TION
lATTY AVENUE .STORAGE SITE
Haze 1 \•Jood , · Missouri
AEC License #SUB 1022 (40-8025)
April, 1971
RETA-~80
…….. -.. -·
RYCKMAN· EDGERLEV ·TOMLINSON and ASSOCIATES
‘,·.
noo coR<'NET cu11.0ING • ;:~5 soGrH. M·." n"M. .£c .~~v·e:uu" •sAINT LOUIS. Mlsso.oni 63105. . . . TI:t.Et'HONF.: (314) 06?.-342.~. ·.:. It is the intent of this proposal. to provide a ~ans \·1hereby th~ Latty Avenue Ore Storage Site may be deco.ntaminated and returned for normal -..,.....---------·-- ··--· land. use \·lith no restrictions on future u5e, in full compliance \'tith all ~~- -""""" . ' · ~ applicable rules and regulations of the Atomic Energy Commission • 2 . ·Figure 1 sho\'/s a schematic of the Storage Site \•lith the stockpiled mate· . rial outlined. This Jlk1terial has had·a long and varied history in re1at~on to its ultimate disposal as outline·d in your Commission's Invitation to · .B id No. AT-{23-2)-52, dated January 10, 1964; At that time a partial·.· · ' : ;· . . . listing of the material included: 74,000 tons of Belgian Congo Pitchb1end. · Raffinate containing about 113 tons of uranium, 32,500 tons of Colorado Raffinate containing about 48 tons of (iranium·and 8700 tons of leached Barium Sulfate containing 7 tons of uranium. Material indicated on· the schematic represents those listed above as purchased by Commercial Dis-. cou~t Corporation of Chicago, Illinois [License #S~1C-907 ( 40-7603 )] • · Since August, 1970, Cotter Corporation has be~n drying and shipping the Congo Raffinate to their site of operations in Canyon City, Colorado. (License No. SUB-1022 (40-8035)]. At the present time this operation is heing completed. L0\'1 concentrations of valuable metals and other elements have rendered the remaining material economi.cally unfeasible to process in like rM.nner. For this reason it is proposed to bury the remaining material on site. The landfill \•Jill be constructed in a series of excavations and burials. . . The area previously occupied. by the Congo Raffi nate \·Ji 11 be further exca- . vated, with the original uncontaminated earth stockpiled in a spoils. ar~a; to provide suffici~nt space for burial of the Colorado Raffinate. The area . . . . . . occupied by the Colorado Raffinate vli11 be made available for burial of .. the leached Barium Sulfate settling pond residue and other non-compressible contaminated material. . · l)il):r: / 1 ' ~;i:J:'(i~. fi~k::; Building "D", refer Figure 1, shall be thoro~ghly \\:;.:.i~ :;~ .~ ~. .: ~:<· J·.r~~--::~ ;::;,. ·~:: j:<• ~ ..= ·.: · .. :~ ~:.:~·.::”:~f:· ~.::·.:::; :. . :.:· ·;: .•: : ·. •. : · ·.::. ..: . ., . ·, :: .· •. ·•·· :. …., :.: :. • • .., · ·: .. !1~ • ……. ;..: ··-=-;.. •• .-.’: ·,.r~· .. , •. ._.:;,_ ,, •. ,. .. –<..- ¢. --·~ . ,. , from the site. Building "N', an office, 118", a garage and dining area, and· "C", an equiprrent storage area will not tequi re extensive decant amination .. Dirt, debris and other material deposited \•lithin Building "011 duti ng the drying operation VIi 11 be r!:moved and buried,. a long \~ith slightly contaminated original earth, on top of the Barium ·sulfate.· The top layer of earth on al1 contaminated areas \•Ji11 be removed and buried until radiation levels have been reduced to be1m·l AEC limits. · 3 Guidelines for the burial pits \•Jill .comply viith good engi~eering practices as \'tell as the rules and regulations of your Commission. A11 pits wi11 be of sufficient size to insure a m{nimum of four feet earth cover·. on the finished installation; All excavations will be sealed on the top and bottom with a four inch (4 11 ) thick asphaltic layer. If 11\•tet" conditions are ~ncountered while opening the pit, a11 sides \•till receive the asphaltic seal. All areas \•li11 be scraped c1ean· of contaminated earth sufficiently d~ep to insure a maximum gross radiation level of 0.05 mR/hr. The entir~ site \'Jill bQ graded to insure proper drainage \·lith no_ unsightl_y nXlunds or dcpressi ons. · It is the desire of Cotter Corporation to reutrn to its Lessor land which will in no \•Jay be 1 i mi ted in its useful ness or va 1 ue and \·till in no \'lay endanger the surrounding environment and its inhabitants. RETA-780 . •. . ... :. ·,·· RETA & 780 Latty Avenue c D CD Settling Ponds FIGURE 1 Sketch not to scale .. · . . . .' . . Colorado Raffi natc ·coTTER CORPORATION LATTY AVENUE STORAGE SITE H/\ZLENOOV, ~flSSOUR I - . ,• 4 :.: .· I ' . . '' ·- - · ·--.--· .. UNITED STATES ATOMIC ENERGY COMMISSION WASHINGTON, D.C. 2.0545 Hr . E. :· • ·’ ·••• ;’,\);:~X,; .\>U ,. ; :. i?.,;\i:J:;ii>:•.’fl’ “”‘·’~'(“~eJf,:%:o:.,~c’6 :;:: ” ;;, ., ., .• • .~’ ‘”” ·· <• ·"'~'' • • •·i' • · ·.' · ... ~(~:.2!;~~ UNITED STATES ATOMIC ENERGY COMMIS$lON WASHINGTON. D.C. 20545 I }.l (., June 28, 1971 J j.!pi r.:·~} r ~ ( ·. ~~ 1:. ~. =- ~ ·; "':"'! • I l . . I I ... ""'I ;. i I H<'·.< '7 . MEMORANDUN FOR THE F ILBS I •".!.~. . .. · ··· · ·· · · · ··· ·· · · , . I y_ .. I SUBJECT: MEETING \'liTH REPRESENTATIVbftOF':1COTTER. CORPORATION . ! . At the request of -Senator Peter Dominick (Colorado), Commissioner· Johnson met \>lith David Marcott, Executive
Vice President, and Ed\vard NcGrath, ~vashington Counsel,
for Cotte·r Corporation on June 2.4, 1971. Ot;hers
a~tending were Dr. Martin Biles and U. M. Staebler.
Messrs~ Marcott and McGrath had previously met with
personnel from the Division of Materials Licensing and
Wast~ and Scrap Nanageme_nt.
Cotter Corporation acquired radioactive residues from
early AEC milling operations Hhich had been moved from .
the St. Louis Airport to Hazelwood, a site in metropolitan
St. Louis, by a Baltimore Corporation which went bankrupt.
The material \·las acquired from Commercial Discount, the
fin.ancer of the orig.in~J. .p.urc.h?Js.c _fr.om the AEC. Selected
materials were sent to a plant .at Canyon City for recovery
of valuable minerals. Cotter has ~bout 15,000 tons of
materials to be disposed of in addition to about a thous and
.drums of contaminated materials which can be disposed of .
commercially at a reasonable cost.· They are committed
t o restore the property on ·which the material is stored
but have found that disposal on-site is not acceptable
under present r~gulations. The $150,000 they had allowed
for on-site disposal is to be compared with an estimate ·
of $2 million they have received from Nuclear Engineering
for commercial disposal at a site about 200 miles ar..;ay.
Mr . Marcott ·would Like to dispos~ of the material at the
quarry formerly usqd by the AEC near the St. Louis
operati.ons which is about -30 miles from the Hazelv10od
site. or: Biles reviewed the situation at the quarry,
concluding that disposal there would not be acceptable.
The basis for the estimate of $2 ~illion for disposal·
by Nuclear Engineering \-Tas not· knm’ln but it did not
seem consistent with the usual ~harge af ~bo~t-$0 .70
per cu.· ft. for commerciu.l disposa l _plus transportation.
(Separate information indicates this estimate may.include
decontamination of buildings at the site.) Dr.· Biles
suggested that ·transporting the material to Colorado
. ………. ·1
‘• ‘ , I
.-.
– 2 –
and adding it to ex~ sting piles of taili~gs there might
be worth exploring since the material .i s similar and.
would be quite small in quantity rela tiv~ t o these piles.
It was agreed that: . . · I .·
I
a) Both Cotter and AEC (Bi les ) \•lould look into
t he feas ibility of di~posal on other tailings
piles (i.ncluding licensing) .
b) Cotter t’lould provide a breakdown. of the $2
million estimate from Nuclear Engineering . . .
c) AE~ (Biles) would i nvestigate the. basis b?ing
used for private commercial disposal —
in particular whether pricing on ~ unit volume
basis ·was reasonable for this kind of ma~erial.
d) Cotter vlould provide a summary of the history
of the material and the contract obligations
rela~ive to ul timate disposal associated with
the various transfers . UO.l•~ l”‘~-~-J .. ~OJ.V .~ :~;:;.
· cc; General · Hanagcr
Dr. Martin Biles, OS
R. O’Neill, Cong. Rel.
H. Nowak, NSM
C .. H~nd~rs~n, DR
•2/, ) 7J .• ~b.£. 6./v’
U. M. Staebler
·-….. -.. – …….. _. ____ …… · ~ · · -· . …. , ..
UNITED STATES
ot J. T.~.·.

Post

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

— PVILIC II’O• ta NiO
TIWfSPOt(T A T10H
ICII:NCI oUID nCAAOLOGY
REPOSITORY–~~ ….. .._..~RCOLLECTION–_;.,;;.;;~—
BOX
NO. ~~-..:~~if–….-~—FO~
ER ~(JeJT~I?I. J uly 26 , 1973
0)4P371’E#~#stfl?~ Sr.~
Dr. !·lilllic.:m E. ! btt
Director
Division of Envirorlirental Control
Tec.~logy
Department of I:nergy
:·7a.shingta1 D.C. 20543
Dear or. ; iott:
-‘IUL ltriP – l -r-
4114 C1oarU …. “·,…, ·- … (31C)m-12111
IQISM_ …
Da ppa, Wt- CSIJt
01., ….
Enclosed is a copy of a paper pre ,:Jared by an AJ:X:. offi cial
in 1967, entitled “liistori cal r-.eviev1 of t he i·!al linckrodt
r.J.rport Cake . :• T’nis i s t he only v.rri ttcn info:t:.mation r
have been able to find on any Uranium nd.l l tailings left
in St • .WOuis.
}:1
If you should f ind any other infoi111ation on this subject,
I v.ould u?preciate yarr sen.d ing zre a <::q)Y . ..:.:..c.. .:..::» 1 • .P le~e feel 5:-ee to contact ne i f I nay :.>e of f’ l'(the~
ass 1s tance to yoo. r- n
N C!2
JPJ\:jj:
Sincerely, co < m ;i 0 - n -1(..~< -F.' ::0 J0<:1v . . • i-at .• 0 ~islative Assistant THIS WfATION'i:IIY rlt1Nl1:0 ON P'AI'CJII MADII. ¥UTH " t:CVCL&D l'lftlla ... .. HISTORICAL REVIEH · OF THE 1-'.ALLINCKRODT AIRPORT CAKE 1~ - .,. _' .. .. . In discussing the history of t~e airport cake raffinates, it is t necessary to define t hem and this has been attempted by the _ :_ simplified f~owsheet given in Figure 1. Mos t of the pitchblende ·; ·p r ocessed by K2lli::1ckrodt was obtained as a concentrate from the ' Belgian Congo in 1944 and was shipped to St. Louis from the Congo in 55-gall on metal drums. The pitchblende was digested in 56 per cent nitric acid (93-102°C) followed by sulfuric acid to precipitate the lead and radium \llhen the ore had a low sulfate content. The precipitate was removed by a string-di scharge rotary vacuum filter and was usually leached with sodium carbonate to remove · residual uranium. The sulfate cake was stored in a separate location. since the Belgians (African Metals ) maintained ownership of · the radium. These residues are•presently stored at the Lake Ontario Ordnance works at Niagara Falls, New York. Some pitchblende was al so processed at Fernald and a similar cake, still stored in silos at National Lead Company in Cincinnati, is known · as Fernald•s K-65 residue . Barium carbonate s lurry was then added to the supernate to remove the excess sulfate . The barium sulfate cake was removed by a continuous solid-bowl centrifuge, leached with sodium carbonate, and also stored in a separate area. · The supernate was made 1 ~ in nitric acid and the uranium extracted with diethvl Pt~~~- : 7ne uranium was stripped from the ether with dilute; nitric acid. ' In the first extraction colu::m a precipitate for.::~ed 'Which was, on ·· · occasion, ~emoved by a Sperry Fil terpres s . The Sperry Cake wa_s __ · · : found to be a good source of protactinL9m-231 and .~u~)processed ~ ' about 20 tons ( about eighty 55-gallon drums) and obtained approximately ~wo grams of protactinium-231. The supernate from the .Sperry Press and the aqueous uranium tails were de-etherized and tr~at ed with a hydrated lime slurry . The s upe~ a te frcm a continuous rotary vacuum leaf filter was di s charg~d to the river, and the limed fraction becawe the airport cake . The cake, up until 1960, was about 25 feec hig~ . and covered three acres. ··•· . . ..... ; ... ~ Organic I i ! HN03 Strip ! Urani uin Product Figure 1 Pitchblende Conce:ltrate v . ·. HN03 Digestion ~. H2so4 ll • Supernate ~ sa++ t Supernate I (J D iethy I Ether ' b . Aqueous --- ~ Ume ! Aqt·-•·->’)\
!11
!12
{13
/14 ·us
••
74)00{;
32,500
1, ;.oo
8,!00
350
117,050
Ta”ble I
Uranium Conten::
{Tons)
…..
;1.13
48
22
7
.-2 • 192
Dascriptio_!l
Pitchblende Raffincte1
Colorado Raffinate
Ba3 S04 Cake (unleached)
Barium Cake (leached) ·
Miscellaneous Residues
1 Estimated to contain
1,775,000 pounds Cobalt
• 2,085,000 pounds Nickel
1,098,000 pounds Ccpper
The i:”:~ten!: ~f tbe s~q~~-~~–fqr … Sale~~ was. tQ. allow private industry
to recover r.he valuable meta1.s: copper, nickel, and. co bait. -The
original request:”for bid offered the bidder several alternatives.
The purchaser could use the existing site for purposes of conca~
tra~ing and extracting a~y d~sired material or he could remove.
t~e residue from the site for processing or utilization elsewhere.
Th.e materials remaining after the purchaser8 s processing operanons
were over could be–disposed Ol: oythepurchase:::-at:l:n~\·]eldon
Spri-ngsdump s1._t_e_wnether ·or rioE pro.cessing .. was·-aone-ontfie-prE:-sc?nt
site o~ elsewhere. The Weldon. Spring·s–Quarcy~Dump-s1te wss a’ pit: ‘~
located in·St. Charles County on Ydssouri State Highway No. 94
. approximately five miles southwest of the \ve ldon Springs plant ~d ~ ~
approximately 30 rni~es frcrn the ai~port site. The site wa~ssible
by truck f~om Missouri State Route 94 and a spur track lead·
off the existing east way of the Atomic Energy Commission’s plant
track system providing railway access to the dump pi·t.
– 4 –
…..
1
In response to a ~equest in 1960, Mound made a cost estimate
based on a pro1uction rate of 1>000 grams of thorium-230 per year
·~ o\·~!7 a two to five-year period on the assumption the airport cake·
. i~ 3t. ~.ouis would be available. Pre.;urnably it may have been
I POE5ib!~ for Mound to obtain the thorium waste stream from the
1 private contractor hot~ever tha cost: estimate was based on start- :~ ,
‘j
‘ j
. ~
ir.g with unprc~~s~~d airport cake~ Inclu~ing manpower, shippi~g)
material, and arnortiza~ion of .c~piLal costs over a five-year
period, th~ estimated cosc of the thorium-230 was about $300 per
gram. At ~hat time, Mound was also instructed to make a survey
of all uranium mills in the country to determine if other potential
sources of thorium-230·existed ‘from which this amount of production
could be economically rnaint?ined. ?his survey is compiled in
MIJ1 .. l439, ~’Survey of Sources of Ionium, Thorium-230,~’ by P. E.
Figgins and H. W. Kirby •
Mound received word in September 1960 that the St~ Louis Area
Office was recommending that the bid be awarded to Contemporary
Metals; a company having a “portable processing plant.,. The AEC
talked with them about their probable process which was to be
‘:. car:ied oqt on site and it seemed that they were interested pri)
mar~ly in the cobalt and nickel. However, they also would have
!I’ a s~de st:ream. for co!’lc.entrating scandium and expected thorium to
. go 1.nto that stream.
. .
Later in 1960, word was received that it was quite unlikely that
tn~ private cont:rac~ would be awarded since the United States
~~ Geologic·al Survey forbid the clumping of the sludges, processed ·
:1 or not, into the quarries in question because of the high proba;
bjlity of contaminating’the Missouri River shortly above the
intak~s for the. St. Louis City and St. Louis County water supplies.
Due to the many· problems, the St. Louis Area Office was contacted
by_Oak.Ridge Operations and asked to hold up awarding any contract
:o~ airport sludge until the long range requirements for thorium-
230 could be fixed.

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

1
~1
Aqt:ecus to
Mound
Adjus~ Addity
I
\~
10 Stage t-~idi-Mixcr
Org~ni~
H~03
<1 ..J>-,.
Strip
~1
Ac.u eous
t
Via
0
ste

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

·.
August: 15,. 1967
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Post

1965-11-05 – AEC – Committee Report on Disposition of St. Louis Airport Storage Site

/ ..
I. THE AIRPORT SITE
The. Commission maintains a 21.74 acre residue storage site adjacent
to the St. Louis, Missouri, municipal airport. The site lies
approximately 15 miles northwest of downtown St. Louis. It is
bounded by Brown Road to the North and East, the Wabash Railroad
main line on the South, and Coldwater Creek on the Vest (which is
also the property line of McDonnell Aircraft Corporation). South
of the Wabash Railroad right-of-way lies Lambert-St. Louis Municipal
Airport and an area occupied by the McDonnell Aircraft Corporation.
Aircraft take-off and landing patterns cross the property. A location
map is attached as Exhibit 1. An aerial photograph, Exhibjt 2,
locates the site with respect to adjoining property.
The site is completely fenced; there is a roadway access gate on the
North-side and a railroad gate on the South side, allowing Wabash
Railroad service to the plant via a spur line off the main line
track. The complete area, with its mounds of raffinate residues,
stacks of drums, hodge-podge of. scrap and temporar.y type structures,
has the appearance of a. typical spoil area common to chemical
indu3tries having residue storage ptoblems.
Consent to use and occupy the tract vas obtained by the Manhattan
Engineer District on March 2, 1946. Title vaa acquired to the
~operty on January 3, 1947, by condemnat~on proceedings for
‘20,000. The property was acquired for the purpose of storing
residues from the Destrehan Street Refinery and the Metals Plant.
The major capital improvements to the site were a concrete pit,
202 ft. x 42 ft. x 16 ft., constructed to store radi~bearing
residues (though it vas never used for this purpose), a covered
concrete pad 45 ft. x 250ft. for the storage of drummed materials
and a railroad siding with loading tipple. A detailed description
of the structures on site is given a·s the last section of this
Exhibit.
The site vas operated by the Manhattan Engineer District and the
Commission from 1946 until J1.1ly 1953. when the operation vas
turned over to Mallinckrodt Chemical Works. Guards were maintained
at the site from 1946 to 1951.
II. SOURCE OF iESIDUiS ON SITE
The Destrehan Refinery started operations in 1946, utili~ing
pitchblende ores and continued o.o this feed until early in 1955.
– 1 ..
EXHIBIT 5
I
I I
II
I . I
___ ..,…. –…. ~ -…. —..t -·–·. ·-·-·————-· ., … ….. … -~—— -·—–··· ….. j
The procurement contract for these ores with African ~tals
Corporation required the United States to store both the pitchblende
raffinate (AM-7), which contains metal values other than uranium,
such as nickel. cobalt, and copper, as well as the radi~bearing
residues (K-65). as African Metals retained ownership of all
uterial except’ .its uranium content. African Metals. subsequent~
transferred ownership of the ~7 raffinate to the Government.
A large concrete pit vas constructed to store the radium-bearing
residue (~65) but was not used for this purpose due to health
reasons. Instead, this residue was stored in drums at the site,.
from 1946 until early in 1948. It was then transferred to the Lake
Ontario Storage Area, Model City, Nev York, in 1948 and 1949. lhe
~7 vas stored on the ground in the open where it remains today,
except far about 350 tons of pitchblende raffinate (A~7} which vere
processed in a small pilot plant facility at Destrehan Street to
recover ionium. This material was processed in 1955-1957 and
returned to the originfl raffinate storage at the site.
The raffinate (AM-10) produced from subsequent operations using nonpi1chblende
feeds was stored separately. A barium cake residue
(AJ-4) produced b.f the refinery is also stored at the site; this
residue resulted from the precipitation of digest liquor with barium
carbonate to reduce its sulphate content. Both of these materials
are stored on open ground. ,
The residues generated by the refinery aggregate to greater than
95% of the material presently stored at the Airport Site.
The other major components of residues were generated as slag from
the reduction step of the metal operations at Destrehan Street.
Two types of this material have been generated. Initially the
reduction. bombs were lined with dolomite. The used dolomite liner
(C-liner) was shipped from Destrehan Street and stored at the Airport
Site in bulk on the ground. Shipments of the dolomite slag started
in March 1946 and continued until early in 1953 when the dolomite
liner was replaced by a recycle magnesium fluorine liner. Approximately
half of the C-liner has since been shipped to FMPC for
recovery of the uranium content.
In 1955 an Interim Residue Plant was constructed at Destrehan Street
to scalp the uranium content from the magnesium fluoride slag produced
in the Metals Plant. tailings from this operation (C-701)
were stored in the concrete pit at the Airport Site, and since have
all been shipped to FKPC for recovery of the contained uranium.
By 1960 there also had accumulated at the storage site approximately
50,000 empty drums and 3500 tons of contaminated stee1 and alloy
scrap. Hovever, by 1962 the bulk of these materials had been disposed
of for the metal salvage values.
– 2-
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……….. -· .. —-·- –~·- .. — ……………… ·-·—·
Approximately 2400 drums remain in the area; these c~ain aiscellaneous
residues, Japanese uranium-containing send and contaminated
scrap materials.
Katerbl presently stored at the site is suamnari%ed belcnn
Gross Tons Approx.Tons U
Pitchblende Raffinate (AK-7)
hffinate (AK-10)
Barium Cake (AJ-4)
Other Miscellaneous Residues
· aDd Captured Japanese U
Precipitates
C-li.ner s 1a g
III. TOPOGRAPHY OF SITE
74,000
32,500
10.200
350
4,000
113
48
29
2
49
The original ground purchased 1D 1946 vas very uneven· and contained
e lov drainage area on the western section of the site. The land had
a drainage slope from East to West, with all surface drainage directed
to the Coldwater Creek at the western edge of the property. The
initial topography of the site is shown in the aerial photograph,
Exhibit 6.
It has been extremely difficult to reconstruct precisely the sequence
and location of contaminated materials and residues deposited on site.
The Committee has collected from various files and from McDonnell
Aircraft Corporation a series of aerial photographs which depict the
transition at the original site to its present state. Various reports,
drawings and sketches were also located which contributed to a general
understanding of the degree of contamination of the site. Numerous
individuals associated with the Airport Storage Site have been contacted;
however, since such a time has lapsed since the active
operation of the site, much of the information obtained by these
verbal inquiries is qualified by \Ulcertainties of memory. .Also, many
of the people who were intimately associated with the site during
its earcy operation are no longer available.
Judging from the knowledge gleaned from the above sources, it appears
that with respect to the western part of the site, early dispositions
of contaminated scrap metal were located in the low areas then existing
on the western end of the property. The scrap metal and other
debris were later covered (in 1952} with dirt received (gratis) Crom
McDonnell Aircraf’t Corporation and worked vi th heavy equipaent to
~ke a level storage area (see Exhibit 7). The reclaimed area is
nov occupied by AM-10 raffinate, drums of Japanese sand and contaminated
rubble and other waste from Destrehan Street •
• 3-

!
,’. :. .
~.
The existence of buried contaminated metal below the present surface
of the western section of the site was confirmed by tes; drilling
4escribed elsewhere in this report. Underground contaminated scrap
is reported to be on the order of magnitude of 50 to 60 truckloads
plus one contaminated vehicle.
the eastern two-thirds of the site presently is covered with mounds
of C-liner slag, raffinate (AH-7)t and barium cake (AJ-4). These
mounds of residue rise to approximately 20 feet above normal ground
level. Drainage from the mounds and the adjoining areas is directed
to the Coldwater Creek.
Drainage waters from the storage area have, in the past, produced
some minor contamination in Coldwater Creek. Continued monitoring
of the complete area and the creek waters, however, has indicated
that significant levels have never been reached and that all radiation
readings are well within permissible and acceptable limits presently
prescribed by .AEC directives and manuals.
A topographic survey map of the site (Exhibit 3) shows the existing
limits of residue stockpiles, the general topography of the remaining
area on the basis of one root contour intervals and the location of
principal structures at the site. The aerial photograph, Exhibit 4,
shows the site essentially as it exists today.
IV. INVENTORY OF STRUCTURES
I
The area is inclosed by a chain link fence. It contains the following
structure:u
A reinforced concrete pit consisting of floor slab and walls,
200 ft. long x 42 ft. wide by 12 ft. deep.
A storage shed consisting of a 250 ft. x 45 rt. concrete floor
pad, with a center wall 7 ft. high and 1 ft. thick running the
length of the structure. The pad is covered with a corrugated
metal roof supported on wood columns and trusses. Sides and
ends of the shed are open.
A single track railroad spur which enters the south fence near
the east end of the site.
A steel and wood· tipple is located along the spur.
A timber drum loading platform, 18! ft. x 8 f’t. x 3!- ft. high,
with stone fill ramp, is located just east of the tipple.
A reinforced concrete wash pad for trucks, measuring 51! ft. x
3Si rt. is located east of the Storage Shed.
1 l
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• • ) .•
– —•-<# ---~------or• 14 -·-----......... ·- -~- -- ·-· ·--- ~-----. . ~.·-· .. ··-·-----·-····-A ____ , • If,. . - A reinforced concrete truck loading platform with tamp is located north of the wash pad and adjacent to the vest end of the Barium Sulfate residue. It is T-shaped, measuring 24 .rt. long x 6Sf ft. vide at the north side x lSi ft. vide at the south si~e. Three single-story wood buildings are also located· on the sitea A 32 tt. x 1~ .ft. office building at the main gate on the north side of the area. A 24j- ft. x 12 ft. guard house also at the main gate •. A 9 rt. X 7 ft. portable guard house located near the south fence, midway of the property. , - 5- . -.. -)..

Post

1964-08-03 – AEC – Request for Bid for sale of residues at Airport Site

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Financi’al and E:>;perience Quenionnaire, pace& 4
be given to qualify bid.
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. : ·. “… 6. : LIS! B.t.m~ r.EFER!:NCZ ————————~–·i · -· —

7. LOCA’l’t v:: 0? l’L:’J\1′ I N l:lUCH tESlD’JI:S \-TILL .r.s PI\OCr;SS!:D .:-.——-
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12. Tli’E U~~DZRSlC;-:!D HtRE’EY C~Rl’IflES ‘l’K..t..T T~ INrO!’.H/·.’riO:\ FlJrJUSl~D /~OVE
lS TaU::~ .hh”D CO:’.f\.EC1′. . . · ·
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co:·lPt.J.·rt: ___________ _
BY:
~ITL~:——————————- : ·
J\O’!’E: ·nz CO~·:”·~ I SSl Ol~ 1\ES::::IWES ‘l’l:t r..IG:i! TO DI SQU/~lF~ /J{Y l’ROSPZC’l”I\’E
!It!>ER OR J.CTUA~ LJ.DDEr. OR TO ‘!’tR!!Il~A’l’t A!·”‘:Y CO:~tr.AC’I’ /.H.\tm:;:D Ir
1’iU.:~t lS 1-. t’AILU!’.t; TO J~Ns:·IE?. THE :FOREGOXHG QU~~TIO:,:s I-‘Ul.LY /J;O
; ‘
TRU~i-:FIJLLY. . . –
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(IF HO:tt SP/.C£ IS HtEDED- P~A$1’:: USE SPACt ntLO!v 0:?. BJ~CK SlDZ.)
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. .. . . .. .::· ( .<:· ... .. . ·... : . ';f= ~no·.:2j· .., '; .· .,{ ...' t: ... ..u . . . l.... ,•~ .· . . · . ·· .-.' . ... :: ·: . .. ·.· ; lnvit..r,;tion l~o. Al'··(23-2)·.S3 . :. · ·:.:· .' ·· ' ·· ·, J>Age 6 · .’ ·: :·· · .•
. . .~ . . : ·-· •· :· . . . . . : ~- . . ! < . . . 1. .. • . . : ' .. ... .. . . : . . ..· .! . · .. \ . ... .. · j ~!'>(: ::ti~. The Bidder b invited, ursed, and cautioned to ittspect
the ~ro~cr~y to be sold prior to sub~itti~s a bicl, Property will ·
.. ‘
..
be av~il~Lle for inspection at th~ places ~n~ timc5 opccificd in the
Invit~tio~. ln no case will failure to inspect ~onstitutc &round~ for
the. ~ithclr~\·:al•of a bi~ after op,ening. .· … .
. 2. Co~~i~e~t.tio~ o! Bids. ~he ~iddcr agrees th~t his bid will not be
\7::.thc-.:~ .. ..-. \::ithin the perioo of ti;·:~e spceif1e6 fo:: the :1cc:e-:>tance the:-cof
follo~in3 th~ opnnin~ of bids {siht~ (60) e’lcnc~r d~ys if no period
be speeificcl b)’ the Go\•errun~nt or by the Bidder but not less than tE’.n
(10) c~l~nd~r days in ~ny e~sa) and th~t durint such period hiS bi~
L.”ill rc:-.~ain firm and il·revo:able. The Gov~rn.~~nt rer.erves th~ right
to rf:ject any or .. 11 bide • :and to \lu.ive sny tcchnicGl defects in bids
“.: . ·: · .
c:~ C:ly b~ in the be.tt int~rest of the Covc.rn.”;lcmt. . .. .. . .· . . • l • · … : .. :-..
3·. · F:c t:” C’n ~ibilit’• fo:- Prot>~rt\’ Sold. The !Jurchaser ess\lJ:\~t. all recpo;”tsibility
·;r.:cs lic:bilil:y for th~ projl~rty 6fter the (i.>te of the Gove:;.·r.:n~nt’ ~
· C!Cct::r-tance. The Covern:nent \Jill exercise itli usual cr.re for protccticn
of · th~ mater i.:J.l, but the Govcrn.”i,e.nt vill not l•e retpon::ible for en;· 1 O!>S
· .or ·d~age frcc .in)’ c~use vho.tso~vcr.
4. ·u.~itr. t’i£!1 O!:’l Cov~~r::-.P.nt’ s Li;:.’!>ility. Except for tre;nsportation chC!rges
~hen a return of pro~cr:y al Covc~r~ent cott is authoriz~d by the
Gc:,v~-rrc.ent. the c:e.asurc cd thi: Goverru;;cr1t’s lit.bility in ar.y ease \;here
· . li~bility of the Goverrunent to th~ Purch~se~ hcs been est6blished thall
not exceed refund of such rortio·n of the purchcsc price ~s· the Go\’crr.. ” :’l:mt
mhy h~ve rcceiv~d.
~ .• .
. . …
. . .
: ·s. O:rr.l ~t~.ter:-.entr t.nd l!odificaticns.. Any oral statem~nt or reprcs bc.:cn e.-:Jploycd or retained to solicit or lil!cure this con~n:ct
upon ‘2.n .oc;rc-e;nent or unGc:’Slancang for .D CC:-:”:.li.ssion. pcrccntaee. b1·o!:cr;~gc.
or conting~nt fe~, exeeptins bon~ fide c•»?lo~ect or bona fide . cstabli~h~cl
cu.”t..·ae.;;c. ial ~se:nc ies mclcgtttc to Cong’:”css o-:
~-;’Ziciu;; Cc.•:::r.~i5sic.onc:t ~hl\11 b~ ~G..~itted to .:ny r.hnre: or p.1t’t of this
eonn·~·~t or to o:”‘)’ b~nefit tht.t rM:.y t~rhe thereft·o:n, unless it: b~ r.r.d~
1.1ith .a corpor01tio:. for ita; g~ncral ben~fit. . ..•
‘!’
‘ . .
• • – j .. … .. .:··
. .. • .··. ~ -.
. :•· ~ . . – .. .. : . . : . . . : …. :<· :.: ·. "; .. : .•· .! •• • •• :· ·. : : ~ . • • . :. ~ - · · '" :: · · · ,: ·. \{- ~::--; · :<' ;;. i · • f > r~·o &ir (
‘.i; :. :., •.• · ~· :, , ~· • > :> •…•. :: · . .’.i .· . ·. ·: ·:. . ..: :f ·[·’,’> :~ r ::}”.:~; ~ i1 o~.· Ro i1T-( 2 3• :;· S3·,.’. : ; .••• ·:;.; : ••
. . ·-8. Disput~s. E~cf!pt as otherwise providrscl in ‘thio eon’trAct.-. any di~puU, ·
·· . · · · eorj~ornine to qu~st’i.on Cl!’ !net ari~’i.ng W’ldc:O t~is ·contract. \·7M.ch ts not
. . : . fis?c~ed of by aeree~ent sh&ll b~ decided by th~ Co:~t!·.o.ctir.z Officf:r 1
: .. .’ .. ~ · : . . \;ho. t;h~l red~ce his ci~ cision to ~ri t\ng and rr..o.il or othert·:is6 !urniDh
_.-:_… ‘ a copy thcreo! to ‘\.be P1.u-ch~~or. Trio decision of the Contract1nh O.f!’icer
. . .
; : ·· . · .. shall ‘bo !i.~.n Lno. co;’)clusi ve \lnless, \li thin thi.l·ty 00) c;ays fro;;1 thG
. ; . ·, .. a~te o.r rE!eeipt of f:UCh copy, t.hc 1\u’ch:.seJ· r.:~ils or otht!n·Ji~a furni:-ho:! · · ·
_ .. . to t-h~ Corrtructing Offi.ccr e wri’t.te·n £’PP9~ r.ddr~~s~d ‘l-o the Co~ds:ion •
. · : .· .·· ~he d~cision of the Co:r:nlsston o:- hio duly auth~riz.ed ropresentativo
:.- ·_- · ·· :£or t’hc determ’i.n<>tion o~ such nppeals shall. be fil1d and conclusive u.~-
. loss cett;J r-r.,ined to hava be. en f:u:udulent, 0!” ca:priciou~ J . or erbi u·~y, 0!”
· £0 g!.”o!:sly errC\:1~ous as ~ecessarUy t.o ir.:ply br.ti .f£ith# oJ.• no·~ suppor~c!
. by subs’t.ent1d evidence. .1n co:n.~ecti c:l ~=i th en~· t.?pe=U. prvcE:Gdi.ne U!H’.-ar
. •’ •’
thi~ eleu:::e) the Purchaser shall be s.!forded en cpport’.!nity to b~ n3ard · .
. . and t(• o.f!er evidence in support o! hi~ a~pecl. • . ~onrling !innl oocisi.on .
. of a disp·ilte. hereunder, the Purch!ser s h ~ll proceed ctiliccntly ltith t.”1o
pcr!orr:Hmce of the contrr..ct cma in accordAnce ‘H.tth th~ Con\.!’~::tine; O!.i’ice~ 1 s
~eci&!.o::l.- · ·· . .. · : . ~ – …. . . . :

· –~ · 9 _- ‘D9.fini ti.o:is .· As u~ed throughout this conu·aet,’ the follOHinr. ~rr..!l ·sh:!ll
‘·. ·.. – · · -~h.:v~ t t)C’ ·mean ‘ins sot .forth belci-1: . .
..- -·
‘. ..: -:·.._ . . . .. .·. ..·. ~. : .. ·;·. .. ‘
:: :·.· . . . …. · .. (1.)
I. o ‘, •: ‘ – , ~- ‘ o o o o
. . .. ::•. ·.
. ; ·. ‘• ,·
0 a • ‘<• 'l'he term r.cont.-ac tir-e Offic~r,, ·v.~Dns the pe:-son c~:ecuttna .tho cont.ract on b ~ hal! of the Oovcrr.,,.:ent ~nd in~l\!de s hie successors or ~y duly ~uthoriz~d rep:-c:entat~ve of such }'>~TSO!lo
‘ • ::a
. .·. :· .-.~ · ·: . .•. . . .
•:
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·; ~.: ·.’<. : · •.. (~) . 'I'he t~l'l!l nco:-:-..· d.ssion, means the Uni t~d States At .o:d.c 'E.'le:-cr . :· . . .. Co~ iss ton cr. z:.y duly· £.uthQ:-ized rcprese.nt ati va thereof J . · ... · . · ineluding th~ Contr~cting Officer except for the purpo~c o! deciding nn ~ppea1 under Pc:ragraph 8 llereof enti t.lcd 11Disputo&11 • J • • ~ .. _. .. . - ~ ... .. : . ·.. . .· . . . . . .:·.•, ;., ·: · . .... -~ ;-: '(';) . 1'he uords 11residues'1 1 11property11 an~ uronte:-i~l{s)u ~1·e used . . . . .. . •: ·.. . :.- .' _. . in~::"chE-.nze .::.bly throuahout this document nnci refer to the · · · :: · .: .. .' · · -_. · · ; . .. · ·' · · ur-nni\l!ll•ba;a-inr; mtlterie.l described in Artielo I. · . . .. · · .·.'·.·.~:.. ·· ·.~··. . : •.. . • =·. . ·. .•...• •· .-: : . . .· . • . ! . .· ... :··.. . .~ -:- ~_ ·:.· . •. : ..- . . · · : ·.:._ .. ·: ~. : -:.·~ .: . : : . . ~ :. ,:·f ... ·. . ._ . . .. • ' ' • • • \o :" ,•· ,; ' ' '•• • '• '' l • .: . • • ._,, .:· -.. : ' • ·, • • ! • • ' .- .• • _:· ; : • • • ·,;. • . . . . ..... . . .. .. .. ·: . . . . ·. . . ..... ; . . . ~·. : . . . . . . . . . . . ~ . : . . . . .• - . . ·. . . . . :. : ~. . ': ·: .. : ' . . ;._ ·.. ·. . ·:··· .. . ;' . : ·. . .. . . . . . . . . : . . ... ·.: · ;D.:: · :_ r :,.. - : ;: ~.;~: .:N::.:\:-;·_!,:.:: :,"~ :·: ·: , ,~_·< -/,~, _::· :·.;.::·:~,)_:.·-.i-:-·:_; ;.·:_·.-•-.·. :: .. ;y:::;s/1·;_:\.}.. : •:.. · . ;:.. - : ; .· · ·• •.. . _._,: .•. :··.~..:. ... :.: ·;: _.:_·... .. · ·.·: .....- ' .. . . ·~- ·• ....... . . ... ·.-:. .':~= .. ~ -· · ... . ··. 0 • • • !': : ' . • -~. . • • •. ~: . . .... . . ~ :···. . . · : . ... · . . . . . . .. . . ·.·.· . . ; .. •.- ~ . . . . , . ·. : .·. . ., .. . . • •. • • • • • j I .-. ·· . . .. ...... . .. :· .. . ' . . • ' . - . . . . . . . ·-· . ~ ·. : . ... . . . .. . :~ ,• :.· . . I. ... ' . ...,, :. .. •' .. . .. ;' .. . . . ·•· .. '· :: : .... ~: . : ... ..: ' ~· . . ·. -. · :. ·· ;:.lnVi1:.atior. No. . . ·.·. -· · · ~-··. ·:· ... Pace s. Js-ce3:=ne! ~ r • -. f • 1 .. .. . . . . . ". ~ ~ •. .. . ·::~ > ..- .:: .·. …. :!. .: ·. .. :
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.= .\: ·.:·· .>· .<·::.~~:.~~·.:)/-·:.'\ ... ·.. . ··:·SPECIAl~ co:mi.l'lO:~S .·: ·: ~·=-·.·~ .'. . · ~<(\:··.~ ···:·.).;~>~·· …. ,’.:. ;. .· .
···: “}. ·.. .. · ., ~. ~ :··, … · … ; :··:·.~.>~:: ·~··; … : …. ·.-: ·~.:;: .. ‘·~·.· … :·!· : … ,·
!;;T!CL::; I •. ~· D!:SGRIPTICf.\ 0? RESI~JES . . ·-.. :· ·: . roxi.rc&W \J~it:hts of :the re~idues hauled to t.he site .frcjn t.he rt:!!incry.
fl’r;ey ao not· incluc.iG ~tone added !or ra’!lps end roods, caT’th ad dod b~,r reh~dlinr.
.p.t t’he’ resida~s, o!’ :m~istu& .c.hai6:ist- ..
~ ..
··· ~:ng levels of these ro&dv:aya arp not indicat1vo of tho dep\::h .of the piles of
. . r,as:pues· a ..”. a.”ly s-ivcn location. l’ho ett.irr.nted urani’.lm conten-t. is ba~HJ~ O.:’\ ~r.
.. · ; · a~CU.”:!\ll.ation Of a·seays t&kE:n on pipe Sllr.i?le::; .fro:n c;.cb b&!’-Ch h ·.as to cr~Jtalit3tiv~ end (luu.ti t~ti va eon tents of the rest dues to be ~old1 l:hich
:: · -are gan~r:.lly ci~teribed as follo;.;osa · . . . .. . .. ···
.. :·.:· … ·. . ~ … ~.-~ . .: =·. ·. …. ,· ·.·. :··.·. · .. : .’·’. ··: :-. :.: .· ·:·-:·. \.
‘•. ·. : . ··~· …… . . . . .· … ·.,·
! .: . . -:· ·:·,
:·. :. •. . … : .. : .. · Pitchblende Raf!inate
: : ~.> ;i~ ·: ·.;< The p~ tc:hb'l'cnde ra!' tin ate is· a resie~e ralHil ttng fr071 p r-ocessinr. · ... . · Bel~ia"'l Congo p~t.chblencle to~uther Hi th other \t~'t.n'i.n.":: coneor:trntt.::::. :' --. ~-~.- : !~P~;~~~ .t-Toss lleieht is 7L,o~,~~~~- con~•i~.i.nc ~bou~ ll) ~c~: , , ... ,.. .. · . A syst.~r.;at1c C~ueer SC::.·):·lin~ pror:rr...'f1 tor t.h:: })itr.hblcnoe rr,£i'ina V3 .... · .'. ·. pil!:s \:e:.s par!'o'!'";:led in J\.l..'1e of 1953. l3a.3ed. O!i thirty-sc1'\"Cn ca"ipl~ · . · .· · .. hoJ.ee \·:hich pro,-l.dcd nin'.:! t~'-six ~n~yti~al s~·~plct 1 the T.i'3t~l •· ;.~· · .,,.: ·~··= ·value:.l·1.n llpproximt:rtely 50,000 tons o! l~es1clue o~:ist.in(t at. thc;.t. ... · ·! · .. · · tiJr.e ~1ere estimated a:; tollo;:s: . · ... : . . .· · .. ; ~·. ·.-. ~·. . :- < ~ !. . :;·~·: ·~ .-· .. . ~.:·. . 1,55'3,0~,:> lbs. of Cob;.lt ..
: ·.· .. · · ·l,B4510:>) lbs. of l:~cl:el · .. – .<· · · · · 9711000'lbs. of Copper ··.: . ~· ;·. · •.. . ·. ·.. ~ .: .. ·:· · .. · . ; .... ; .. . .-'.: ~ .... . .; .. · ·'. · .. ~ . .. . . . .. .~ -~ ~. . '. .. • · .. ·.!' .. . . ..... ~ ·. .. . . .... ·. ... • -· ·. " .... · ... . · · .. .. ..- : . . .. .•· Subscc!uent aodi't.ions or r.uff1..r,ato to th~se piles increaEcd the: · .. · . &ross· ,,·eight to appro.xitr.atc.ly 7L.,OOO t{ln.G •. Assumi.""lg t~.e eoppe::- J cobcl. t r..nd nicksl content o!' ·the pitchblC=:'lde o-::-o processed dl!rirJe t..'lis pe.rioc \:~s tbe sa..,le as procescod prior t.o Juno 19$3 1mci neglect:ing any cont.ributi on t.o the lllGtal v.:a.lues bl ot.hsr urr.niu~ .. con~ainlnc llit:t!rials proc~ssed durir1g '\his period; 1-he 'total t~t.

    ·o …… . lb.c. C’! 2,08$ 1… 000 lbs. of
    l,098,.oo~ lbs. of
    .. .•. Cobal’t .. · .
    l:ickel
    Copper
    .. .. · . · . .. .. .. .
    ..• ..·. .. ·.
    Ot~e:- sample’!:! on \lM.. c.ll more c.omplota analyse~ vere rnado are> shC”·1:n
    .in 1’tlblo I. D.1e to t.ho het.cro~ancity of ‘t.h~ [Jitehhlc:md~ r,a!’!’int.ot-s,
    ~he~~ ~nalyses .shonld be· consiclcrt;d indi.oat;i.\•E: 6! the cornposi ‘\..io:\
    -…

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    . ·. V20 .. . . . ;, .
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    . 0.2
    . 0.62 · .
    l.l
    76.17
    A~, I~=~ B., Ba , ne, B11 Cd, Cr, Cu, GA_. In, X, N’o, St., ~.’l,
    · Sr, ll, Y, Zn l’.nclZ::’- till los:- tha.”‘l 0.1% o~>.ch.
    . …
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    tl~c pi t-chbl~n~e rc.f!ina~.
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    ·.: :··: : . · .. · .. ·. :·· … ‘ .:/<·,:· :;.~-:-.- ··. : In,•it4ltion. 'No. AT-(23-2)-53 . . ··.:.· · :- . · ~-. ;: · : . >. .: –< .; ·· .: · ,·:.. : ;:'._.: .:. -~ ~ ·_ :. : Pa"e ll · : : · · .. ·, .· ... • .. ·.,: .. ' , . : .... _. :·:.:.: ... ·;~ .}.~:.C.·~t<.:·,~:::. ·:. ·:, u , : . ·. ·'·:,-; . ..-: ... ·· . -·: .; ~ ·.!• .• ,• 'I .· <:r.~ : ._.:::. t'· :. :s~t-i~~ · sulfate Calte ·{Un1esehed) -·· ...> >::·.·-~ ._:_.; ·.. …. ·: ._:·.- >. ../ :.
    . ~ .. ·-~ . .
    .. ·. · -~~ri~ ~>ulfate cake ‘(unleac:hed) is a resioue result ins freh.l the
    .. …….. :.’ :.·. · … ..
    . …….. : ..
    . · .. ·
    . . .. . ·. · . ·ref ir.ery opei”ation, Approxic;01te gross \Oc:ight is l, ~00 tont conte.in• .
    ins about 22 tons of uranill::l. Compo&ition of the cd~c is c&t im~ted
    · · :. ·· · ,· }:: ·. ‘es f oll o”‘s : · ·- … . ..;_::.::.~·:=:·. ~ . · . _; -_:./ ·_ :.’; · ..
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    . -.. ·.: ..
    · · . . . · .. .. ,’. })llriuo Sulfate · ·.· :;”:: :·· ./· :·. ·’ 60-SO%
    ·:· : . . : .-… ::·• · ‘ .H20 .::_. ·.:’:’-~_: . . :· .. .’ . 15-SS%
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    ·:
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    · ~: .· · Un:mium · · .. · ·- 1′!2 1.
    · · .. •ii:;c. Pb, cu. Ni, Fe, ete: · · 1-2 1.
    .. . ,._. . ··. Solicls- J'()ck. &rav.:!l, Dttnd, ct.c •. .’ 1-2%
    · .. ···. . . . ~ ~ ~ ‘
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    ‘ – ::. ·: . .- L&rium c: ~ke (leachecl) is Zl re&S.duc resul tin ~ frm the refitH:ry or>e.’rlltiO;:’l •
    J.ppro.,.imatc gross weight is 8, 700 tons concd.nin& obout 7 tor.:; of . . .
    uranhsm, Cro.position of the c.ake 16 et:tir.t.t!::~ately . 2 . to:1s
    ·-·drums. l~o othe:r inforfi\.stion is
    .· ·.
    a s~oss ~;isht of ~p~r~xim~tely ‘ 350 to~i
    of uranium are stored in deterior~ted
    nvail~ble ~n theto rcsid~es.·
    ·- :_· ., /~’TlC!.!: I1 – QU.t..l~TI’n.FS ‘l’O B!: f.~·!OVEU
    …. ..
    . ·: . · .. :· :
    . – . ‘
    ·· :··
    ..
    ..
    ..
    ‘ ‘
    -All l:leterid lyi ns ,_,ithin the cro::s-hatched src.ns ~ho~m en D•~·.~inc No. 6·1403-H •
    whieh is ~ttae hed hereto Lnd u.nde s part hereof. chall be re~;•ovc d by the ·
    Purchase~ . I f advnn t~seous to the Purcha&er , he m~y rc~ov e ~ n~ r~sidue s lyins
    ~edi~tely o utside the cross-botched &reas. ‘ ·
    . . ··
    · ;· J.ll· reddues al:,ov.; groun&:1 level &h all be r£:movccl \dthin the cross-hatched
    .. e.re~s. In c~ se of oisagree::1ent on cround lc\•e.l clcv<:ltio4ls, they shdl be establishet b~ procucinz 2' contour&'fro~·clcv~tio;:'l s taken along pe~imctcr · fence ~ral ~ssut:\in6 tt.ere is uniform ch~nse in cle·vat ions olons the north-south grid line!:, lf £adv~nt~geous to t.he Purch::scr, he rucly rcr.\ove rc:.icluec Clnd/or. eontar1inoted e .nrth below cl~tcr.!li:le " .cround level. .. . .. Stone end other debri s c.ontaincc1 in th~ r e Sidue piles tnay be left Ot:\ t he site in dcsiznc:.tcd · ar ea~ c::st~blished by the· Contr.zcting O!ficer. l1po:-~ cc:n?lctio;t of tile p'u r chs:.er ' & rc:noval oper.ation, he shL~ll lett\'C the erercccntat.ion, c>:pressed oi
    W?licc!, £ S to the kind. size. weisht, ‘ludity. eharaetcr, de ~ cription, o:-
    : .. .·: ·. .· .· co:1dition of the rr.ateri~l; o:- its fitness for any use o:- pu~po&c; cr th~t it
    · · · · uill not c£ute injury or d~cge to pe-rcon:; cr pJ.·operty; or that t:ny i n fo!’r:.l:.tion
    · : ~ (incluc:Hnz t he 2:-~ a lysis, a part of the .rlc&criptio:l_, G£:t fo’!”t:h in . /~rticle 1)
    ‘• · . furni&t.e<1, its contE;...tn i nation, ot· other m&tters \.:hich t:..:y c:o:~cer<) it 16 .ee ~i'letc .. :·:.·. or ac e~~ ~te; ~r.d the Govertt::lcnt sh~ll not be hcrty
    · ..
    · .. purchll!;Cc! her”undcr. · · · ·. · .. · ·
    ‘ . .
    • 4 • ,. : • ‘: . .. ·. . .
    .. · ..
    • ·: •• : • 0
    .. . ·.· .. ,··.·
    , · , .: . : ··The resioue:. dctcribed herein con&titutc Gouree ~st~ric.l, the receipt, pos –
    . · .session. u~e Ot’ trantfer of uhich arc C\\bjN~t. tc H.c~nsinz r c:qui.n::uents Lnd
    … : .·. ·reguhtio:ts pr~ul&ated by the CC::::l\issi.on pun:u~nt tc the Ato:nie tn::::rgy /.ct
    . • _of 1954, ~s o::-ended (1~2 USC 2011). Accol·dintl>·, pureh~se-rs must obtl’.i.n s
    licen~~ 2n d cc:::;,ply \~ith the r equirc.:::enu of the regulc.tion.c pc:rt6ining t.o
    sou-rce ·material as set -forth in 10 CFR, l’artt ·20. 40 end ?0. . … . … . ~ . . . .
    … . .
    ~· · .!,!:.TlCt~ VI – t:OTlC!. ‘!’Cl PrtOCErJ> &nTH . Jl.~·:Oi.’.~l. AllD ‘I’X!·:E rc~ rJ:-!0\!f.L
    . . .
    The G o verr;::)~nt vill i ssue a notiee to proee~d with respect t.o l’C!:\OV:!l of
    : ……. , … ..
    . . ..
    . .
    •.. ·. · .. ::
    ·.· .. :.
    -rcsici..!O C, In no event sh.e.ll the Purchr.sC:\r l’c:r.ovc the rcs:i. ciues p:dor to cuch
    notice to proeeed.· “The Cover~~cnt vill not 1s£ue c notice to proceed prior . · ~:
    .·to the P~Tehaser’s o~tainin; a license as re~uired in Article V ehove. . 1 . .
    J.fter notice to proceed, the: Purchaser thP.ll r~:love the n~~idut!S \lithin 400
    caler..da~ clays ,
    . ·• . ·: .
    . . . .
    The Purchaser ~hall be re~:.Jhcd to fur nich i1 P crfe>~'”t.~:1nec aond in the c:ount
    of ~sc.ooo guZlr~nt ce inz the ·l.ciUo\·al o ‘f all retoichle&;. ··
    . . .
    !:El.C’L”=- V!Il – PAYl;:!:NT
    P … y.~.~nt pf the· pu1·ch~sc p.-iee ~htll h~ m::.dc \1ithin 30 dc.yc fr c;~ the otlte t>f
    r oacci!’t. o! rtotie~ fra::. the Go\’crr-“‘::cnt to .proce;ed vith the r~:.1 ov~l of t he
    pro;>crty •
    .· ·. :•
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    .. … .:.. . ..· .. .. .- .. .-” .· .-. . . ~ ·’
    •• 0 •• •
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    .Title to the propct·ty sh:.ll pnu to the Purch.,::cr upon pa~”;:)ent of the
    ·put: eb~se· price ~s providcJ in l.’rticle VIII above and furnisbin~ :Pcdo:-c~nee
    ~ond ns rec:l.!ireci in Article VII abt>Ve ~ . . – .. · f · .-:. .. . ~:~·· . . .
    . : :·. .. ~- …. .
    •· … ·. ~ .. ~ ~ – . . ..·; ~. ‘ .
    ( .
    ~ –
    . ~- J.s el£~\<7h.;;re pro\'idcd herein. the property sol'~ her~und~\: is 11£6 1&11 • ~- "'whet'c 1s11 and all 1 o.ldin& and rcmo\'l:ll cf . tha propert;y ~h-!!ll be ::lt tha · '•· .~ C):!,)enue of the PurchD&cr. ... .. ..·.. · · · · 1 l\w..;. · . . ·" . .• .. . ... ... . gTICLE XI - 0~-sr.r:: PRCCESSHlG · · · . . . . \~ ) . · ·- .. . . 'The Pu:-ch ~ ser ~ay ·perform on.-site precessing O?erl\tions follo~inz: · .. cubje.et to the .. .r '.I\ . ;: ~ .. . a. ·The PurchasE:r shall furnich at his O\m e.Y.p~r.se all processins eqd.pment :' .. :·.-. ·_' ... . 'a~d·provic3c ~ll · .ttruitu.res neeeSSC.l')' !or _cn•Si.te procer.sirg operati(Jn.L . : . . ·: ·.·· ~ . ... .. . -~ .. · · b. All processing .cquir.::.Jent • and ·t>tructures inz.tellcd fqr pro:cs£ o?eration.
    ·=’ , ·. ·?,1 · shell be re:!l.oved by and at thll c;.;pcnse of the rurchOl~el’, !pr~ptly upon
    ~ .. . · _.~ ~ – -~O’llplet ion of the \-10:::.”k. ~ ·
    ·.::·· -~;_ · … • . . . . . . — ~
    . <·:;~. c· . . Use of the.sitc fo:: on-site processing sh.sll not ere~to en)' .right,· ': : :·:. ~ ·title or intere.st .. to the site prop~rt:y in the Pm:chcser o:her than the · :· ; . · ·:. · ritht to p~rforr.l proccssins opet'o:t:ions thereon. . ; .· =, . . ·.· ..... · Cl. lor any The Purchaser s~&ll not .use or perr..it the use of any pDrt of the s i te other than on-site processing. The Purcha~er may not astign o:: tran~fer rig.ht of use of the site to others Yithol.lt the .approval of the Cc=ission. . . · ·.' e . · "r.ailir.g~ resl.!lting : frc:~ on-site procestin~ o! quantities of cotcri~ls ·.: .. - : . rec;ui'red to be r~ovcd • . es pr~vided in Articl e II .ebo-..e, _ &'t-.~11 be r~:n~vcd > · _..· fro;n the . site. : ..
    .· •t” .• ; ._. … .. £. “l’he Purchaser shall ee:uply ,with all Feocr~l, : Stat~~ County ,md· loc&\l
    la~s. ret,’1.!lations and ordinances. . .. . . . . .. : ·•
    . . g. : The Pl.lrehaser shall not construct or otber’lo’ise place upon the site
    . .. · an:; stru~ture abov~ SSO ft. elevntio:;; me:m sea level (approx~t~ly lS ft.
    :. . .. · abov~ troun~ level). · _ . ·. . .. , . – · ·
    . .
    h • . ~he Purch~s~r shall do nothing ~hieh ~111 interf~rc with lo~din£ C-line’t’
    £l02g 0:1 :t· ~il c:2rs by ·the Co!:::lission or its desisnee for off-site £h;:”,p~ent.
    This ~ateria 1 h located on th~ c~st end of the propert)’, ll& ~ho\m on
    l·:C~! t>rc.”.lint l~o. 6-1403-19.
    I ‘
    • • .-. • .,.j~ … .. _ •••••
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    -··.

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    . i
    .:·
    · .. ‘ . … . E·_~:(fO 2 ~ l’
    I
    . . “·
    ~· ‘.’ .. Invitation No •
    Pa~e 14
    }.’r-(23-2) -53
    ·• .. ..
    . ·: .
    1. The Purch~ser sb;.ll l>C: responsible’ and liDble for and .shllll. snve
    Govern~~nt h2nnless fr~ ~11 ~uits, ~lDimS and ~~ages of’~hatso~ver
    .a:-isi’:”.g cut of or in eonne~tion vith \:o.r. k perforr.1ed o~ the .site,

    I
    th~
    kind
    that CovBrnmcnt p1·operty ~onsisting
    of’spp~ox~atcly 21 acret £t-~obertson, Missouri. 1~~~dintcly north of
    ‘l’he· term .,sitE:” as used herein “cec-ms
    St. Lo~is l·!~mic’i.pal .Airport Qno east of l!eDo:mcll J~ircra~t Corro:~tion Plant
    ·on »ro•~ Road, ~ll in St. Louis Co~nty.
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Post

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

STATEMENT OF WORK
Independent Technical Review for Operable Unit 1 at the West Lake Landfill Site
1. BACKGROUND INFORMATION
The West Lake Landfill Site is on a parcel of approximately 200 acres located in
the northwestern portion of the St. Louis metropolitan area. It is situated approximately
one mile north of the intersection of Interstate 70 and Interstate 270 within the limits of
the city of Bridgeton in northwestern St. Louis County. The Missouri River lies about 1.5
miles to the north and west of the Site.
The Site consists of two radiologically contaminated landfill cells comprising
Operable Unit 1 (OU-1) and the Bridgeton Sanitary Landfill (Former Active Sanitary
Landfill) and several inactive areas with sanitary and demolition fill that have been
closed comprising OU-2. Land use at the site and the surrounding areas in Earth City is
industrial.
Other facilities which are not subject to this response action are located on the
200-acre parcel including concrete and asphalt batch plants, a solid waste transfer station,
and an automobile repair shop.
The Site was used agriculturally until a limestone quarrying and crushing
operation began in 1939. The quarrying operation continued until 1988 and resulted in
two quarry pits. Beginning in the early 1950s, portions of the quarried areas and adjacent
areas were used for landfilling municipal solid waste (MSW), industrial solid wastes, and
construction/demolition debris. These operations were not subject to state permitting
because they occurred prior to the formation of the Missouri Department of Natural
Resources (MDNR) in 1974. Two landfill areas were radiologically contaminated in
1973 when they received soil mixed with leached barium sulfate residues.
The barium sulfate residues, containing traces of uranium, thorium, and their longlived
daughter products, were some of the uranium ore processing residues initially
stored by the Atomic Energy Commission (AEC) on a 21.7 acre tract ofland in a then
undeveloped area of north St. Louis County, now known as the St. Louis Airport Site
(SLAPS), which is part of the St. Louis Formerly Utilized Sites Remedial Action
Program managed by the U.S. Army Corps of Engineers (USACE)
In 1966, residues associated with the production and refining of uranium
materials were purchased by Continental Mining and Milling Company of Chicago,
removed from the SLAPS, and placed in storage at the Hazelwood Interim Storage Site
(HISS) on Latty Avenue under an AEC license. In 1967, Commercial Discount
Corporation, which obtained possession of the HISS property and residuals, began drying
residue and shipping them to Cotter Corporation in Canon City, Colorado (DOE 1987).
WLLFOIA4312- 001 – 0058946
In 1969, residues remaining at the HISS were sold to Cotter Corporation in Canon City.
In 1970, Cotter Corporation dried and shipped some of the remaining residues from the
HISS to Canon City (DOE 1994). In December 1970, an estimated 10,000 ton of
Colorado raffinate and 8,700 tons ofleached barium sulfate remained at the Latty
Avenue HISS.
Reportedly, 8,700 tons of leached barium sulfate residues were mixed with
approximately 39,000 tons of soil and then transported to the West Lake site in 1973.
According to the landfill operator, the soil was used as cover for municipal refuse in
routine landfill operations.
The geology of the landfill area consists of Paleozoic-age sedimentary rocks
overlying Pre-Cambrian-age igneous and metamorphic rocks. The Paleozoic bedrock is
overlain by unconsolidated alluvial and loess deposits of recent (Holocene) age. Alluvial
deposits of varying thickness are present beneath Areas 1 and 2. The landfill debris varies
in thickness from 5 to 56 feet in Areas 1 and 2, with an average thickness of
approximately 30 feet in Area 2. The underlying alluvium increases in thickness from
east to west beneath Area 1. The alluvial thickness beneath the southeastern portion of
Area 1 is less than 5 feet (bottom elevation of 420 ft/amsl) while the thickness along the
northwestern edge of Area 1 is approximately 80 feet (bottom elevation of 370 ft/amsl).
The thickness of the alluvial deposits beneath Area 2 is fairly uniform at approximately
100 feet (bottom elevations of 335 ft/amsl).
A subsurface oxidation event (SSE) is ongoing in the South Quarry Landfill
portion of the Bridgeton Sanitary Landfill. The South Quarry cell is connected to the
North Quarry cell which is adjacent to Operable Unit 1, Area 1, one of the locations on
site that received the radiologically contaminated soils in 1973. Pursuant to an order
from the Missouri Attorney General, the site owner is required to install a subsurface
barrier between the North Quarry cell and OU-1 Area 1 to prevent the SSE from
migrating into the radiologically contaminated materials.
As a follow-up to EPA R7 consultation with EPA’s National Remedy Review
Board (NRRB) in February 2012, the following evaluations are being conducted to assess
the Remedial Alternatives for OU-1: 1) partial excavation evaluation; 2) alternative
landfill cap designs; 3) evaluation on the use of waste treatment technologies, including
apatite; 4) recalculation of RIM volumes for a full excavation scenario; 5) groundwater
fate and transport modeling; and 6) recalculation of discount rate. These evaluations will
be contained in a forthcoming Supplemental Feasibility Study (SSFS) Amendment or
equivalent document.
WLLFOIA4312- 001 – 0058947
II. OBJECTIVE AND SCOPE
This will be an interagency agreement. The EPA is requesting assistance from
the US Army Corps of Engineers (US ACE) to conduct an Independent Technical Review
(ITR) of specific documents associated with Operable Unit-1 at the West Lake Landfill
and being developed in response to National Remedy Review Board (NRRB) comments.
The technical support may consist of performance of specific tasks which USEP A
contractors have neither the expertise or cannot provide at reasonable cost to EPA.
III. WORK ASSIGNMENT TASKS
USACE shall furnish personnel and services required to conduct an ITR of
reports prepared by the Responsible Parties in response to the recommended NRRB
evaluation.
Tasks included in this scope are:
1. Project Planning and Support
2. Independent Technical Reviews
3. Community Relations Support
4. Close-Out
TASKl PROJECT PLANNING AND SUPPORT
This task includes work efforts related to project initiation, management, and
support. Activities required under this task include the following, as applicable:
1.1 US ACE shall participate in a scoping meeting with EPA to discuss the work
assignment.
1.2 USACE shall provide proposed level of effort and costs for the support activities
to be performed. Based on EPA’s review of the scope, level of effort and cost
estimate, USACE may be called upon to participate in negotiations with EPA on
the proposed level of effort and to revise the level of effort as a result of these
negotiations.
1.3 The USACE shall perform site-specific project management including:
1.3 .1 Establishment and maintenance of necessary work assignment files,
schedules, and project documentation
1.3.2 Provide monthly reporting and invoices. These documents shall contain
WLLFOIA4312- 001 – 0058948
narrative of specific task and subtask activities sufficient enough for the
EPA Remedial Project Manager (RPM) to evaluate the work assignment
progress.
1.3.3 Monitor costs and performance
1.3.4 Coordinate staffing and other support activities to perform the work
assignment tasks in accordance with the Statement of Work (SOW)
including USACE subcontractors, if utilized.
1.3.5 Attend necessary work assignment meetings
1.3 The USACE shall accommodate any external audit or review mechanism that
EPA may require. Level of effort for this work will be determined at a later date
and this IA will be amended to include this task and associated cost.
TASK2 INDEPENDENT TECHNICAL REVIEWS
This task includes the work required to conduct the ITR and documents the
required deliverables.
2.1 US ACE shall coordinate and prepare a review plan and assist EPA in preparing
the reviewer’s charge statement.
2.2 US ACE shall perform an ITR of reports prepared by the Responsible Parties
(RPs) in response to the NRRB consultation with EPA on the Supplemental
Feasibility Study dated December 28, 2011. The purpose of the ITR is to
provide an independent assessment of the RP’ s work products to ensure the
scientific and technical components have been applied in a sound manner to meet
established regulatory requirements. The ITR will be conducted by qualified
individuals who are independent of those who performed the work, and who are
collectively equivalent in technical expertise (i.e., peers) to those who prepared
the reports.
The reports prepared in response to the NRBB recommendations will include:
2.2.1 Up to four ITR reports to address the following:
• The RP’ s evaluation of a partial excavation alternative;
• The RP’s recalculation of RIM volumes to address alternate excavation
scenano;
• The RP’ s evaluation of up to three alternative landfill cap designs;
• The RP’ s evaluation on the use of up to five waste treatment technologies,
including apatite and soil sorting;
• The RP’s results of groundwater fate and transport modeling; and
• The RP’ s recalculation of all alternatives using a 7% discount rate.
2.2.2. A Supplemental Feasibility Study Addendum or equivalent document.
WLLFOIA4312- 001 – 0058949
2.2.3 A Revised Proposed Plan, if required. If a Revised Proposed Plan is
required, the level of effort for the ITR will be determined at a later date and this
IA will be amended to include this task and associated cost.
2.2.4 An Amended ROD, if required. If a Revised ROD is required, the level of
effort for the ITR will be determined at a later date and this IA will be amended
to include this task and associated cost.
2.3 USACE ITR team will review historical documents for familiarity and
understanding of the site. Historical documents will not be the subject of the
ITR. Historical documents to be reviewed include, but may not be limited to the
following:
• OUI Site Characterization Summary Report
• OUI Remedial Investigation Report
• OUI Baseline Risk Assessment
• QUI Feasibility Study
• OUI Supplemental Feasibility Study
• OUI Record of Decision
• EPA Radiological and Infrared Survey Report (ASPECT) (May 20I3)
• MDNR Radiological Survey Report (May 20 I3)
• Radiation Management Corporation Radiological Survey (I982)
• NRC Radioactive Material in West Lake Landfill (I988)
2.4 US ACE shall prepare an ITR report for each of the documents reviewed. The
letter report will contain USACE’s technical evaluation and, to the extent
practicable, shall be written in terms understood by the general public. The letter
report will be submitted to EPA as a “final” product. The number of days
allotted for completion of the ITR will be jointly determined and agreed upon by
EPA and USACE based upon the size and nature of the document to be
reviewed, but shall be no less than 45 calendar days for any review.
2.5 The USACE ITR will focus exclusively on the scientific and technical aspects of
the documents and whether the scientific and technical components have been
applied in a sound manner to meet established regulatory requirements. It will
not address grammatical, editorial, or formatting aspects of the document.
2.6 The US ACE ITR team shall participate in one technical meeting with EPA and
the RPs for each of the documents reviewed. The purpose of these meetings will
be to provide clarification on any comments. These meetings will be conducted
in the St. Louis area. If not able to be accomplished via an in-person meeting,
the meeting shall be accomplished by phone and internet (Web Meeting).
2. 7 EPA shall furnish US ACE with the following:
WLLFOIA4312- 001 – 0058950
2.7.1 Background documents, data, and other information necessary to ensure
the ITR’ s completeness;
2.7.2 Notification, at least 30 days in advance, of submittal of a document for
review
2.7.3 A tentative schedule identifying anticipated document submittal dates,
review times, and meetings.
TASK 3 COMMUNITY RELATIONS SUPPORT
This task includes efforts related to community relations support to EPA.
Activities required under this task include the following:
3.1 Upon issuance of this IA, USACE shall attend two community meetings to inform
the public ofUSACE’s support to EPA under this IA and answer questions. For
the initial public meeting after IA release, USACE will prepare a Power Point
presentation or other visual aids, as required to communicate the ITR process to
the public. For the second public meeting after the IA release, USACE shall
attend to answer any remaining public questions regarding the IA scope.
3.2 Upon completion of the review of each document, US ACE staff shall attend a
community meeting and present a description of the work accomplished by
US ACE and the findings of the ITR. The presentation will be provided via Power
Point, or via other means, if required. An electronic file of the Power Point
presentation shall be furnished to EPA at the meeting. USACE shall furnish 50
paper copies of the PowerPoint presentation for distribution to the public.
3.3 USACE staff shall be available to participate in pre- and post-meeting public
availability sessions for the meetings at which the USACE reviews are presented.
USACE shall provide necessary public availability session displays and
information packets (up to 50 handouts of Power Point presentation).
3.4 EPA, as lead agency, shall be the central point of contact for all project
stakeholders. If requested by EPA, US ACE shall provide written responses to
written questions received by EPA from the community regarding USACE’s
scope of work for the ITR effort.
TASK4 WORK ASSIGNMENT CLOSE-OUT
This task includes efforts related to work assignment close-out. Activities
required under this task include the following:
4.1 Upon notification by EPA, the USACE shall begin all internal procedures
necessary to close out the work assignment including any file duplication,
distribution, storage, or archiving per the contract requirements.
WLLFOIA4312- 001 – 0058951
4.2 The USACE shall return documents identified to EPA or other document
repositories as directed.
IV. WORK ASSIGNMENT PERIOD OF PERFORMANCE
August 1, 2014 to December 30, 2016
V. STATUTORY AUTHORITY
The statutory authority for entering into this IA is Section 105(a)(4) of the
Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) of 1980 (42 U.S.C. 9601 et seq., Public Law 96-510, December 11,
1980), as amended by the Superfund Amendments and Reauthorization Act
(SARA) of 1986 (Public Law 99-499, October 17, 1986), and Executive Order
12580.
VI. SCHEDULE OF DELIVERABLES/MILESTONES
TASK DELIVERABLE
1.3.2 Monthly Reports/Invoices
2.2 ITR Reports
VII. EPA CONTACTS
N
Project Manager Dan Gravatt
Project Officer Ina Square
SUBMITTAL SCHEDULE
Throughout period
Per agreed upon schedule
913-551-7324
913-551-7357
WLLFOIA4312- 001 – 0058952

Post

1967-09-30 – Mallinckrodt – Fuel for the Atomic Age – Report on St Louis-Area Uranium Processing Operations

~ V~Lit~S\f\~J)
w~~~
. .
•mpletion Report On St. Louis· Arta Uranium Processing Operations, 1942 -1967
~ I
LEGAL NOTICE
This report was prepared as an account of Government
sponsored work. Neither the United States, nor the Commission,
nor any person acting on behalf of the Commission:
A. Makes any warranty or representation, expressed or
implied, with respect to the accuracy, completeness, or usefulness
of the information contained in this report, or that the use of any
information, apparatus, method, or process disclosed in this .report
may not infringe privately owned rights; or
B. Assumes any liabil ities \IIi th respect to the use of,
or for damages resulting from the use of any information, apparatus,
method, or process disclosed in this report.
As used in the above, 11person acting on behalf of the
Commission” includes any employee or contractor of the Commission,
or employee of such contractor, to the extent that such employee
or contractor of the Commission, or employee of such contractor
prepares, diss eminates, or provides access to, any information
pursuant to his employment or contract with the Commission, or his
employment with such contractor.
-II· * * *
This report was prepared by Fleishman-Hillard, Inc.,
St. Louis, Mo . , under Mallinckrodt Chemical Works -Uranium Division
Subcontract 25188-M of July 11, 1966, as modified. The report
was prepared in connection with Mallinckrodt Chemical Works’
performance under Contract No. W-14-108-Eng-8 (Principal Contract),
as modified, with the United States of America acting through the
United States Atomic Energy Commission.
,,,
FUEL FOR THE ATOMIC AGE
Completion Report On St. Louis-Area
Uranium Processing Operations, 1942 – 1967
September 30, 1967
I.e !
TABLE OF CONTENTS
Page
Section I, Fuel for the Atomic Age (General Summar~ . …. 1
Section II, Technological Developments
Part 1, Commercial Reduction and Casting of
Uranium Metal. • • • • • . • • • • • • • • • • • • • • • • • • • • • . • 8
Part 2, Development of the First Commercial
Process for Ether Extraction of
Uranyl Nitrate . . . . . . . . . . • . . . • • • . . • • . . . . . . . . 18
Part 3, Development of the Continuous
Ether-Extraction Process .•••..••••…. •• .• • 25
Part 4, Development of the Tributyl Phosphate-
Hexane Process for Uranium Purification . … 32
Part 5, Development of the Pot Process for
Converting Uranyl Nitrate to Orange
Oxide . . . . . . . . . . . . . . . . . . . . . . . . . . . . . • . . . . . . . • 42
Part 6, Development of the Fluid-Bed
Denitration System .•• ..•• ••• •.•.•• . • •.• •••• 49
Part 7, Development of the First Factory
Process for Producing Brown Oxide …. .• … . 59
Part 8, First Factory Production of Green
Salt in St. Louts . ••…••. •• • … •. .. • ••.•• • 65
Part 9, Development of the Continuous-Process
Stirred-Bed Reactor for the Production
of Green Salt and Brown Oxide .. •• .• ••• ….• 72
PartJD, Advances in Continuous-Process
Production of UF4 – Development of
the Integrated Fluid-Bed System •••••.•••..• 81
Part ll, Development of the Dingot Process
for Producing Uranium Metal .••• .••• .• •• . .• • 96
I
Sect ion II (continued )
Part 12, Development of t he Electrolytic
Reduction Process .••..•.. • • • • • .• • • •..• … 109
Part 13, Miscellaneous Technical Developments •• ••• 114
Section III, Organization & Management
Part 1, Organization and Management •.••• • • ••.•••• • 118
Part 2, Material Accountability ..••..•• • • . • • • • • • . • 132
Part 3, Plant Security •••••••.••. • ••• . . . •.. • •.. • •• 136
Part 4, Heal th and Safety.. . . • . . . . . . . . . . . . . . . . . . . . 144
! · Section N , Producti on and Cost …… .. . . .. … … .. …. 157
!
Section V, Conclusions •..•••. • ••..•. • .. •••.•••..•.. •. . • 164
Bibliography . . . .. .. . . · …. . . . . . . . . .. . … . … .. . . , . . . . • . . 167
I .e
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i~:~:::~~;};L;;}~;c~;,i:~·::L:&tX~::::.YK~:~’!J:f:¥i!;if/}1~~~:.%\tt::/NDk~~&.:~:;.;/t.~~>t ::·::.;:.~::·~-;~·. -.’ ….· . :: ·:. ,· .. .· I ~\l-. :J •• …. ~.,.1,.., .. .,,,_. ….. , ·><~""· ......... ~.-.• ·J·~·>‘·••·~ •~t,.J~ .. -~•’-‘·}~”.i!’;,wQ~) ~~·~··,,,. … f>.; …. ,.., ….. ,., •• _,.,.v, .• , …. :l.;, • .• ~ . ……. ~ ,.,., ,,, . •. , .. :· . .. •.• ..
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·.
– 1-
Section I
FUEL FOR THE ATOMIC AGE
An Introduction to the History
of Mallinckrodt Chemical Works • Uranium Production
and Development Activi ties
for the United States Government
11The story of the supply of uranium
is by itself a thrilling one, and
the production of enough pure metallic
uranium to do our task in time was a
technological and industri al miracle. 11
—- Arthur Holly Compton*
j * Arthur Holly Compton, Atomic Quest (New York : Oxford University
1 Press, 1956), p. 90.
-2-
On December 2, 1942, in the early days of vlorld War II,
the atomic age was born: the first self-sustaining, nuclear
chain reaction was achieved in what had been a squash court under
the West Stands of Stagg Field at the University of Chicago . On
that day, ” … man first liberated and controlled the power
within the atom. This event was known only to a few . To those
few it was a turning point in history, the birth of a new era.”*
The historic and dramatic accomplishment on that cold,
winter Wednesday in Chicago was the successful result of the
combined work, talents, and skill s of scientists, engineers,
technicians, and others working on related, super- secret projects
in various parts of the nation.
One of the most important parts of the hush- hush
scientific – industrial complex was the uranium project at the
Mallinckrodt Chemical Works plant in St . Louis, Missouri . Its ·
work was a vital link in the chain of activities which led to the
birth, and subsequent development and advancement of the atomic
age .
This document is a history of the Government’s uranium
operations in the St. Louis area. Officially, it i s €1. “completion
report” describing Mallinckrodt 1 s operat.ions from July l~ 1942,
through June 30, 1967, under Contract No~ W-14-108-ENG.-~ for
the United States of America. To provide perspective, the report
discusses significant event s and activities from Martin Heinrich
Klaproth1s discovery of uranium in 1789 to Ma llinckrodt’s initial
involvement in uranium-processing research in the spring of 1942.
It continues through the termination of the Company’s standby
contract with the AEC in June, 1967 .
Figure I is a chart summarizing the major contributions
of the Mallinckrodt organization to the Government ‘ s uranium
processing and development efforts in the St. Louis area during
the 25-year peri od from July, 1942, through June, 1967.
*Ibid . , p. 139 ·
-3-
TWENTY-FIVE YEARS OF URANIUM PROCESSING AND DEVELOPMENT
MAJOR CONTRIBUTIONS BY MALLINCKRODT CHEMICAL WORKS
* First Commercial Process for Ether Extraction of
Uranyl Nitrate
* First Factory Production of Orange Oxide from Uranyl
Nitrate
* First Factory Process for Producing Brown Oxide
* Early Production of Green Salt
* Early Commercial Reduction and Casting of Uranium
Metal
* First Stirred-Bed Reactor for Continuous-Process
Production of Green Salt and Brown Oxide
* First Commercial Continuous Ether-Extraction
Process
*
-1<· * * * First TBP-Kerosene and TBP-Hexane Processes for Uranium-Ore Refining Numerous· Advances in Uranium Metal Production, Including Slag Liner, Dingot-Extrusion, and Electrolytic Reduction First Successful, Commercial Fluid-Bed Denitration System First Integrated, Continuous-Process Fluid-Bed Uranium Production Adaption of Uranium Processing Equipment to Commercial Production of Purified Dense Theria Continuous Cost Reduction Through Advances in Manufacturing Practices and Scrap Recovery Consistent Fulfillment of AEC Production Objectives Figure I -4- . ~ Objectives Of The Report . e I The objectives which guided the preparation of this report were: (l) (2) (3) (4) (5) To provide a single document describing the major aspects of the technical and administrative history of the Government's uranium processing operations in the St. Louis area. To explain the rationale underlying the technical and administrative developments of the operations. To produce an evaluative instrument for comparing and appraising present and future operations of a similar nature. To provide a general guide for the establishment of similar operations in the future . To organize a one- source reference on the highlights of the first major processing contract to be phased out in line with the Government's evolving requirements. (6) To contribute to the literature in the fields of uranium-production technology, nuclear science, chemistry, and technical and administrative management. The report is \'lri tten in a semi- technical tone to make it meaningful and useful not only to persons with technical backgrounds, but also to those whose orientations are not primarily technical. Summary And Organization Of The Report This report consists of five major sections . This section, Section I, is an introduction and general summary of the entire document. Section II, which comprises the bulk of the report, is a history of the philosophy·behind the major technological developments of the St. Louis-area uranium operations. The emphasis of the material in Section II is on the rationale underlying the developments rather than on detailed descriptions of the developments themselves . The _ detailed descriptions can be found in a variety of other technical reports and documents . I I . -5- Because the uranium effort in the St. Louis area was primarily technical in nature, the history of the operation is, in large part, a technical history. It began in April, 1942, when Dr. Arthur Holly Compton, Dr. Norman Hilberry, and Dr . Frank H. Spedding approached Edward Mall+nckro d~, Jr., to seek his Qompany's assistance in preparing the extremely pure uranium compounds wnich were needed as fuel for an experimental atomic reactor at the University of Chicago. The reactor, if successful, would achieve a self-sustaining nuclear chain reaction. The whole project was of extreme importance to the national security. At the time, the United States had been engaged in World War II for nearly a year, and the nuclear reactor experiment had the potential for making a major contribution to the war effort. A successful nuclear fission reaction, on a proper scale, would release an incredibly enormous amount of energy, and could produce an explosion of immense proportions . The possibility that scientists of the Axis powers might develop a device to achieve such a frightening explosion made imperative a vast effort -- the Manhattan Project -- within the United States to develop such a device first . It was in this tense, wartime environment that Mallinckrodt was asked to produce the key uranium compounds which were needed before fur t her progress could be made. Dr . Compton and his associates at the University of Chicago already had approached several other major chemical producers to ask their assistance, but they all declined -- partly because of other wartime commitments, and partly because of the difficulty and risk involved in the uraniumpurification assignment. To produce the needed uranium fuel, impure uranium concentrates would have to be purified by extraction with ether . Never before had the extraction been achieved on anything but a laboratory scale, and even on that small scale, the explosive and erratic nature of the ether made the operation extremely hazardous, Dr. Compton turned to Mallinckrodt because he was familiar with the Company's outstanding reputation for safely producing highquality, high-purity products, and because he knew that the Company was expert in handling ether. Mallinckrodt accepted the challenging assignment, and within 50 days, the Company accomplished the "remarkabl e achievement" of producing highly purified uranium oxide on a tonnage scale. -6- At that time, the Company's uranium products included, uranium trioxide (U03, or orange oxide), and uranium dioxide (U02 , or brown oxide ) . Later in 1942, Mallinckrodt started production of uranium tetrafluoride (UF4, or green salt). When the first self-sustaining nuclear chain reaction was achieved on December 2, all of the uranium in the pile was in the form of uranium dioxide produced by Mal linckrodt or uranium metal prepared by others from intermediate materials produced by Mallinckrodt . A few months later, in July, 1943, Mallinckrodt started its first metal plant. During the 25 years that it was involved in uranium production, Mallinckrodt made numerous contributions to uraniumprocessing technology . This report discusses most of the Company ' s major contributions including the development of the first commercial process for ether extraction of uranyl nitrate; the first continuous ether-extraction process; the tributyl phosphate-hexane process for uranium purification; the pot process for converting uranyl nitrate to orange oxide; the fluid-bed denitration system for producing U03; the first factory process for producing brown oxide; improved methods for batch- type, factory production of green salt; the continuous-process, stirred-bed reactor for producing green sal t and brown oxide; advances in conti nuous- process production of green salt by means of the Mallinckrodt integrated fluid-bed system; improved methods for casting and reducing uranium metal; and the dingot and electrolytic reduction processes for producing uranium metal . Section III is a history of the administrative development of the St. Louis-area uranium operations beginning with the initial efforts in 1942 in Mallinckrodt 's building 25-2 research laboratory and continuing through the final act ivities at the AEC 's Weldon Spring facility in 1966. The subjects discussed in Section III include organization and management, Mallinckrodt ' s experience and qualifications, contractual arrangements, physical f acilities and plant services, material accountability, plant security, and health and safety . Section IV deals with production and costs. In addition to discussing cost accounting, the section provides an interpretive narrative concerning Mallinckrodt- AEC negotiations, and other pertinent subjects related to production and costs. Section V is a brief statement summarizing the conclusions of authorities concerning the significance of the work accomplished since 1942 by the Government's St. Louis-area uranium operations . .e .e -7- For almost a quarter of a century, Mallinckrodt successfully carried out its uranium-processing contracts with the Government, The Company, always surpassing its commitments under the requirements of the contracts, continually worked to lower costs, increase production and improve quality. In April, 1966, when the AEC announced its plans to terminate its St. Louis-area uranium production activities, Dr. Glenn T. Seaberg, Chairman of the Commission, praised Mallinckrodt for its excellent performance in the Government's atomic energy program. He called attention to the Company 's outstanding record of accomplishment for production operations and related process improvement and development programs. Dr. Seaberg said that Mallinckrodt 11can be justly proud of the important role it has played in the advancement of Re aceful uses of atomic energy and in our nation ' s defense efforts . 1 # '•. •,, o 0 fo •, • ,:.,• ,''••• .. : ..... • ' • ~ t .. • .... • . ... • ..... • ~ . .. .: ," , .·. ':', :. . ' , ¥ ••• • ' •• ·1 • •• ' • ~ :· ....: ',. ..; :~·:·:_(~:;. .: <;;.: ..: >~’- />_::::_ .> ..> . .: .. ,; . ·.· ‘·. ..
.. , .. ..
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…… Section II .. . ..
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‘~.r!~.~-:;:~;:~~;_~~~–::·_ ::~ _-_;_~~~::_~_,:_~_::·_:~:~>~;-~-~-~-·::~-·_ ·_· : …. \~. …f .~._-_<_- -·._---)_::::-.......: _-;.:·:;·...: j:~-·-=: <<.· -~~::<:-:~ ...·. ·:. . ,.- -............. ~~::·.,:·:.:.~ ........ ·' .· ... ~~ · ... --~ - :-_.:,- ··.::\ rr:. .. .... .: : ·:. ,. ...: . . .·. -:·. :.' ,' :r ·:: '·?· '· .... . ... , • ·• .. :. ·-::-:-·.· .. ,'j: . . .... ' :: . :.:.·_ ·: . .:::: ·:· ~-·· ··: ... : : :-· . .. .·· . ... . ...·..· . . . .. · .· .' .. .... .. .. . .. , .-:,_: · • . . ; • ..;': ~,: •. :· .... - •. •• -.• • a.i ; . ; •. ;-::. :.; .: .. : : ·: .:.:. • .. •.• ,-. • ., tl •• •••• : • • : • • '··\ • • • •• •• · :. ~;. - ...: _ :: :. -::-::--·;::_ <·;' ::· (:~?:~·i.-;':. ':_,.·; .· .-: ·:·-.· ;,:·~-' ·... -->~-·. ._· .:·_. .1
:_-:/ :: ·:.:~t::=·~·;·:·~:~::,~~~-} } ·,,/:?-::·:::·-<~:-:~:·.·::. :'.~.: . . ... - ....... . ·' ...... .. ·. ...... :. .. ..: .. .. .., . ... _:.!.·~;.~~-... :__ . .. ·;.£. .. • ' .... : •••• :. · .. • • .: • • ' .. ::·' "' .... •• • • 0 ': . ; • 0 0- • .... ·:· ;·:,:··.·:; -::-:•· . ..-.-<~. • :. .. . +·: :. : ....... -, ... ~:.·_:.·:·:, .\.;·.:;I-'~_:;-.. :~~~>: .::·–~·. .: :>_-;·” .. .
..· …
··-
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·.···.
~~~*~~~~~~~~~~~~~~~~~~~~~~~~~~~~J~~~~~~~~*;~2~·;·~~~ ~~t~~~~~:~J~ … ‘7i … , … 0 •••• • ••• ,. -·.
• 0 0 0 0 ,o, :.o: . t· .. .·. .. · ·.. . . .. . , ….
~~~~mif:r~i~·~~m:i~~~t-J.!~~;~·.:. :-:,:0··=-.· ::{·.- :;_;·:_·:.:;~~:i:/:::_~;;.-:~ ;-~,- ~: -….
. · .~:~ ·!·.:~.’-· -~-:~:·:.~.~-.. ~·/. ‘:·: -~ ;’ “.\
..,.,.-,;J~.~::·,:.y::, 93, 172, 186, 190, 192, 198, 199, 201, 211, 222 ,
223, 224, 225 .
Additional references may be found in some of the sources
indicated above.
#
– 25-
Section II
Part 3
DEVELOPMENT OF THE CONTINUOUS ETHER-EXTRACTION PROCESS
· In 1945-46, Mallinckrodt Chemical vlorks developed a
continuous ether-extraction process for purifying uranium, and
designed and constructed a large, tonnage-scale plant using the
process. With continuing improvements, the proces~ remained the
standard one at Mallinckrodt’s St . Louis operation until 1957
when tributyl-phosphate-hexane was introduced to replace ether.
Background
The original batch ether- extraction process, developed
on a crash basis, had several disadvantages. (The batch method
is discussed in detail in Section II, Part 2 . ) Chief among the
disadvantages were high operating costs and low percentages of
uranium recoveries . Further, removal of certain contaminants
from the uranium was insufficient, and the method required
relatively pure concentrates, which made extensive prior processing
of the starting materials necessary .
The New York Operations Office of the Manhattan District
initiated activity to explore the possibility of overcoming these
disadvantages. The office assigned to Yale University the task
of investigating the possiblities of a continuous ether- extraction
technique that would use feed solutions prepared directly from
pitchblende by nitric acid digestion .
The Yale work indicated that the approach might be
feasible, if a number of complicated inherent problems could be
solved.
Initial Development Work At Mallinckrodt
In the spring of 1945, as the Yale studies were being
completed, Mallinckrodt began research to develop a final, continuous,
counter- current ether-extraction process. Work was aimed at finding
a method-which would use feed solutions prepared directly from
pitchblende ores, or crude concentrates containing 30-80 per cent
black oxide.
I i .
– 26-
Mallinckrodt had to solve several complex problems,
some of which were revealed in the work at Yale. The major hurdles
were to:
– develop satisfactory methods to prepare
suitable feed solutions . ·
– cut down on impurity (especially molybdenum)
carry- through during extraction.
– ge.t more complete recovery of uranium.
‘rhe total job was two-fold: ( 1) development of workable
methods for preparing suitable feed solutions; and (2) research,
development, and design of the continuous extraction process and
equipment.
Preparation Of Suitable Feed Solutions
Mallinckrodt worked on developing two methods for
preparing feed solutions — one with pitchblende (containing
radium) as t he starting material, and one using radium-free
concentrates.
The method that Mallinckrodt developed for processing
pitchblende involved several steps . First, the original material
was ground, and then it was digested with nitric acid . The
resulting solution, however, contained -radium and sulfate , both
of which presented additional problems .
The radium posed a problem both because of its inherent
radioactivity hazards, and because of its high value . The sulfate
if not removed from the solution — would cause precipitation and
mechanical difficulties during extraction .
Mallinckrodt found techniques to overcome these problems .
The excess sulfate in the digestion batch was removed by precipitating
the sulfate with barium carbonate which also coprecipitated
the r.adium as sulfate . The precipitates were removed
by centrifuge techniques, leaving a feed solution with little
barium or sulfate.
Mallinckrodt’s preparation of feed solution using chemical
concentrates free of radium or sulfides and containing only
relatively small amounts of sulfate or calcium, involved simply the
digestion of the concentrates with nitric acid. The resulting
slurry, after adju~tment of free nitric acid and uranium content,
was used directly as the extraction feed .
-27-
One obstacle remained in the preparation of the extraction
feed . It was incomplete uranium dissolution. To dissolve the
uranium completely required an excess of nitric acid. During the
extraction process, the ether stripped the aqueous feed of acid
and this caused precipitation to occur . The prec ipitation, in turn,
caused sludging and emulsion which interfered with proper operation
of the extraction equipment. Mallinckrodt 1s solution to the
problem was to add a controlled concentration of nitric acid to the
ether to prevent the stripping.
Pilot Plant Development Of The Continuous Ether-Extraction Process
In addition to solving the problems associated with
developing feed-preparation processes, Mallinckrodt also had to
solve major problems in developing the extraction process itself.
In the spring of 1945, a pilot plant was built as an
annex to the batch ether-extraction plant then in use. The pilot
plant was used to carry out the extensive experimental work leading
to development of a practical, continuous, counter-current , dualcycle
ether-extraction process — one that could be translated into
a plant system.
In terms of the physical chemistry invo l ved, the continuous
process that Mallinckrodt developed was basically identical
to the batch process. An aqueous uranyl-nitrate feed solution is
dissolved in diethyl ether . Then the ether and water layers that
form are separated, and the purified uranyl nitrate is recovered
by further treatment of the e t her solution.
The continuous process developed by Mallinckrodt had two
cycles: (1) acid extraction, and (2) neutral extraction . The
process is illustrated in Figure II-3.1
Acid Extraction
The first stage of.the acid cycl e was the extraction
column, a tube packed with small cylindrical sections of ceramic
pipe to promote intimate mixing of the aqueous feed and the ether
phases. The ether was the continuous phase and was introduced into
the column at the bottom. It flowed counter-current to the aqueous
feed which moved by gravity from the top of the column . After
·passing through the extracting column, the uranium-enriched ether
phase overflowed from the top and was carried by pipe to the
bottom of a wash column.
The ether solution carried with it traces of impurities,
some of which were dissolved, and some of which were mechanically
entrained. (Part of the molybdenum, because it is soluble in ether,
was one of the impurities that was carried through.)
hffi noto
Solvbft ~lrott•
N.O. IIqvor
to Acid htJo<~on F.H Acfl"tlloont -28- WothWotor RoH'nott Coke Rhlolt to Acld$owor Produd Figure II-3 .1 THE FIRST COMMERCIAL CONTINUOUS ETHER-EXTRACTION SYSTEM was developed by Mallinckrodt as a dual-cycle process. -29- After it left the extraction column, the uranium-rich solvent stream was then passed through the wash column where small amounts of water were used to remove some of the impurities in the solution. · Re-extraction was the final step in the acid-extraction cycle. Large amounts of water were introduced into the top of the re-extraction column. The aqueous phase, f lowing by gravity from the top of the column, mixed with the uranium-rich solvent \'thich flowed counter- current to the water from the bottom of

Post

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

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

Post

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

‘ .>v~-:tt~ Tll l>oE ‘l/Y/’<~ m.o. 1 History of Material Storage at the St. Louis Airport ~torage Site Tnis is a sumnary of tne licensed mdterial that ha' s been stored at the ~t. Louis Airμort Storage Site (SLAPSS). The site is also referred to as the Robertson Airport Site ano as the St. Louis-Lambert Airport Property. The ~1.7 dcre tract is locatea immediately north of the airport, and since l94ti has been used solely for storaye. 1~1ost of tne mater1als stored at tl1e site were resioues genera~ed by tl1e Mall inckroat Cnemical Works during uranium prossessing operations for tne Atomic Energy Co1unission from 1946 to 1953. The t"1anhattan Engineer District (MtO) was grantee consent to use ana occupy the property on Maren 2, 1946; title was acquired by conae1nnat ion proceedings on January 3, 194 7. Table l sumruar i zes the mater i a.1 stored .H. the SLAP$S. Most mat er i a 1 was removed from tne site in tne 1%6 to 1%9 time ftarne, alt11ough some contaminatea wastes were buriea on site. The pitcholende raffinate, AM-7, was a proauct of operations at the 1~1alli11c1y 1~59 as
a result ot operations by MallinciLAt>SS consisr.s of bJried scrap and
wastes. Jecontami nation wastes, n .. t>b I e. and scrap from remov a 1 of bu i: 1j in gs
at Ues tren,rn Street between 195 7 and · %2 are buried at the ·;o1es t end of the
si:e. In aodi~ion, all structures at the SLAPSS ri€re razed in 1969 anu
Duried on site.
3
Table 1. Materials Stored at
St. Louis Airport Storage Site
Desi gnation
Material fnt ry Inventory Reports
Apri I ‘959 { 1 ) June 1960 (2)
Au9ust 1964 {2)
Uranium Uranium
Tonnage Tonnage Tonnage Tonnage
AM-7
K-65
AJ-4
AJ-4
AM-10
C-6
V-10
C-701
Notes,
Pitchblende raff inate
Radium bearing residue
Barium sulpnate cake, unleached
Barium sulphate cake. leached
Colora~o raff lnate
’46 – ’55 (4)
• 46 – • 48 (4)
’46 – ’55 (4)
’46 – ’55 (4)
’46 – ·ss (4)
Vitro residues ’54 from Middlesex
Captured Japanese U,
C-Liner slag
precipitates’54 from Middlesex
Interim residue plant tailings
55,000 30- and 50- gallon drums
steel and alloy scrap
waste, rubble, and scrap
structures on site
’46 – ’53 l5)
begin ’55 (4)
by • 59 ( 4)
by ’59 {4)
(6)
bl.Ii l t ’46 – ’59
——-
74000
0
1500
8700
32500
290
60
7800
7000
3500
(1) Reference: Airport Storage Inventory — April 11, 1959.
——-
113.2
0
22
1
47.6
1.9
o.z
122.3
144.4
(2) Reference, Invitations for bids, U.S. Atomic Energy Commission,
St. Louis Area Office, June 10, 1960, and August 3, 1964.
(3) Reference~ U.S. Atomic Energy Comm\ss\on survey, November 1965.
(4) from Oestrehan Street Refinery
(5) from Metal Plant at Plant 4 and Metal Plant 6E at Oestrehan Street
(6) from removal of buildings at Oestrehan Street between 1957 and 1962
(7) to Lake Ontario, New York. storage site
(8) to Cont1nental in 1966, transferred to Latty Avenue, Missouri, and
disposed of at west Lake Landf; 11 by the Cotter Corporation in 1973
(9) portion sent to Fernald In early 19GO’s; remainder to Continental in 1966
(10) buried at west end from 1957 through 1962
(11) razed and buried on site in 1969
——- ——-
74000 113
0 0
1500 22
8700 7
32500 48
350 2
{inc I. in above)
0 0
November
Tonnage
——-
74000
0
1500
8700
32500
350
(inc 1.
4000
0
1965 (3)
Uranium
T__o nnage .._ ____
113
0
Z2
7
48
2
in abovtt)
49
0
Disposition
’66 to Continental
’48 – , 49 ( 7)
’66 to Continental
(8)
’66 to Continental
“66 to Continental
’66 to Continental
(9)
to Fernald ’59
sold oy ’62
solo by ’62
( 10)
( , 1 )
.. … –
F:o..,, r:IJ’ ::I-?)
CHAPTER 2 ~l/”1′ ti”” ._A_s-re_
SITE DESCRIPTION c_/a’!1~t’f,’CA-r”i-~
4FJ:tM~1)t. ~
The purpose of this chapter is to describe the Latty Avenue
site at Hazelwood, Missouri, the characteristics of the contaminated
soils and structures present on the site, and the local
geology, hydrology and meteorology.
2.1 LOCATION
The site is located in north St. Louis County within the
corporate limits of the city of Hazelwood, Missouri. It is on
the south side, and at the western end of Latty Avenue, with a
·street address of 9200. The site is 2 mi {in a straight line)
north and slightly east of the control tower of the Lambertst.
Louis International Airport. The site is part of Lots 11
and 12 of Hazelwood Farm, a subdivision in U.S. Surveys 1 and 2,
Township 4·7 North, Range 6 East, St. Louis County, Missouri.
(See Figure 2-1.)
2.2 TOPOGRAPHY
The total site, comprising approximately 11 acres, is in low
rolling hill terrain at approximately 520 ft above sea level.
It is in the drainage basin of Coldwater Creek, which discharges
some 12 mi downstream into the Missouri River. The variation in
elevation on the gently rolling site is approximately 10 ft. The
site is separated from Coldwater Creek by Right-of-Way lands of
the Norfolk and Western Railroad Company. Figure 2-2 is a descriptive
map of the site vicinity and includes topography of the site.
2.3 OWNERSHIP
The site presently is under two ownerships. The westerly
3.498 acres are owned by Mr. Dean Jarboe of St. Louis; he purchased
the property in June 1977 from the Bayliss Company, which
in July of 1976 purchased it from Associate Commercial Corporation,
formerly Commercial Discount Corporation. The remainder
of the site {approximately 7.5 acres) is owned by the Norfolk and
Western Railroad. (See Figure 2-3.)
2.4 HISTORY OF PROCESSING OPERATIONS AT THE SITE(l)
In early 1966, ore residues and uranium- and raditllll-bearing
processed wastes which had been stored at the St. Louis Airport
fill site, shown in Figure 2-1, were moved by the Continental
(l)See end of chapter for references.
2-1
.. “\.’• ..
….
Mining and Milling Company of Chicago, Illinois to the Latty Avenue
site. These wastes had been generated by Mallinckrodt Chemical
Works of St. Louis during the period 1942 through the late
1950’s. The Commercial Discount Corporation of Chicago, Illinois
purchased the residues in January 1967: much of the material then
was dried and shipped to the Cotter Corporation facilities in
Canon City, Colorado. The source material remaining at the Latty
Avenue site was sold to the Cotter Corporation in December.1969.
Records indicate that residues remaining on the site at that time
included 74,000 tons of Belgian Congo pitchblende raffinate containing
about 113 tons of uranium, 32,500 tons of Colorado raffinate
containing about 48 tons of uraniwn, and 8,700 tons of
leached barium sulfate containing about 7 tons of uranium. During
the period August through November 1970, Cotter Corporation dried
some of the remaining residues at the site and shipped them to
its mill in Canon City, Colorado. By December 1970, an estimated
10,000 tons of Colorado raffinate and 8,700 tons of leached barium
sulfate remained at the Latty Avenue site.
In April 1974, an NRC inspector was informed that the remaining
Colorado raffinate had been shipped in mid-1973 to Canon City
without drying and that the leached barium sulfate had been transported
to a landfill area in St. Louis County. A reported 12
to 18 in. of topsoil had been removed with the leached barium
sulfate. However, analyses of soil samples taken during an NRC
investigati~n of the Latty Avenue site in 1976 indicated the
presence of uranium- and thorium-bearing residues; furthermore,
at some points on the site, direct readings of radiation exceeded
criteria established by the NRC for decontamination of land areas
prior to release for unrestricted use.
On May 30 and June l, 1976 articles appeared in the St. Louis
Post-Dispatch which indicated that there were some discrepancies
in the official records as to how much contaminated material from
the Latty Avenue site had been deposited where. By letter of
June 2, 1976 the Director, Division of Enviromnental Quality,
Missouri Department of Natural Resources, inquired of the NRC
about this matter. During the June 22-24 and August 11, 1976
periods, Region III of the NRC investigated the alleged discrepancies
and reached the following conclusionsC2l:
ft.0.9.QO#Jt 1.W .. tM _ –
(a) About 8,700 tons of leached barium sulfate and
almost 39,000 tons of soil were removed from the
former licensee’s Latty Avenue site and buried
under 3 ft of other soil at the West Lake Landfill
in St. Louis County during the period July-October
1973.
{b) The material present at the West Lake Landfill
does not present an immediate radiological health
hazard to the public.
(c) It is estimated that the concentration of natural
2-2
•• **™ I #WWW&–
‘ C, 7
/ )
13
I I ( ( I I
f o o oo –0 C.O r’4 ,pP ..-r-o CO
~ 1co -c ( 1 c–~C()f) ~ > 1-:-
i)e ~ f /.”i ke.
,…o I l S{‘ ~ A1’v’fof’t”
{Re~c~
rvt~{ ~~,(.q (
– ~.’ft_~ 3 (tr’,/fs
– \e-o v\l.tov~Q {f oY-t’
c~tlrtv.~ ~ .Plw)
/t:/f 2- – 19<7 ~ , ~ f>O ‘s – .ft~ , ·Pue ~ 51:) (/)
fo ~V\(t~&-tA( u,~t~_j
-r4’0oo 112’· 02.._ >
:>t,fo~ .ti~
..
(i) 32
Table l . Uraniwn residues store airport (],> l\1J1… “‘~1” ht
site (November 1965) ~ -J
~~~~~~~~~~~~~~~—“ep”–3v~e ~O
Waste material
Pi tchhlende raffinate > AM,7
Colorado raffinate) /tM—10
Tonnage
74,000
32,500
Uranium
tonnage
11 :>
48
if l>OO /13
}’21 {oe; 4~
.,.a.~ r\1′”‘f £Barium sulfate cake, unleached
ft’ I i,t)C “”ur
Barium sulfate cake, leached
1,500 22
8, 700 7
(I £Ou t’L
i, t(}(J 7
-r~o
‘· ~
‘z.
– –
~1isc<:llaneous :naterial 350 ., - C-Ljncr slag 4,000 .< (1 ""-' Total 121,050 241 :t.V\i'tl~"'"' ~es~Jk 1'f~-t ~: !\'"':>~,
v;~,4 ~e$~~,_~
G-IO(
CAf’t~ “;Jc~~ ~ -,:>(l>c.-; rt’-t’\-t~s
Structures and other facilities On site (Nove:rr.be!’ 1965)
Reinforced concrete pit 200 x 42 x 12 ft
Storage shed (concrete flcor) transite roof)
Railroad spur
Loading platform (concrete)
Truck wash pad (concrete)
Thr~e single-story storage shacks (wood)
Chain-1 ink fence
~ {,tXJo ~viM$
sw.Q. +-a.\ I~ $if0i_ f
3>5’0 ;z.
Uxt-Jf~-~ MerJ~ G’f ·
/ 96 :
I t cft’ vo ‘”V~ ~ (J 9 3 ‘t:4-“S U~ ‘ft. )
—!II-~ c~ -:”-“Re–ef–·~ =-:!!~.————
:r:G ~llU-r’j,.-t,O…, ~rt No. 76 -c/
1-..f-17
al I s 1eo -t fea.J.e.R ~.’w-. .s·Arha-re-
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-tl:t(._ s 700 t; -~ 70: I +’/OA—
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SW”‘~ . -L~M,-1[ w~ ~1~
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.,,.,.-~-···~—-~— 90!~•06 … __J _ UNITED STATES GOVE.R NME.N. T
Memorandum
TO
.FROM
SUBJECT:
Files DATE: September 25, 1962
R~&-J.-t. ~4>-1/Ul Ronert L. LayfiE91 , Source & Special Nuclear
Materials Branch, Division of Licensing & Regulation
PRE-LtCENSlNG VISIT TO THE CONTEMPORARY METALS CORPORATION
PROPOSLD FACILITY AT HAZELWOOD, MISSOURI, AND RESIDUE STOCKPILES
AT ROBERTSON, MISSOURI• DOCKET NO. 40-6811
The Contemporary Metals Corporation was awarded a contract by
the AEC fer the removal of uranium-bearin~ residues from stockpile
areas at Rcbertson, Missouri. These residues were generated
by the Comu.ission at its Destrehan Street Plant, St, Loui~.
~issouri. The applicant intends to process tf.ese ~esiile site. In additic:-i to r:.c: .. r::C:s c.f resi..::.;es,
the ?olo!’ad? raffi:-iate ~ unleacl.’ed bari’..:n s~lfc.. e ~~h. ar.d
learlum cake resulting from refinery c~·er~1:1or:s. 2:-:G rn1scellanecus
redc·..ies st~re~ in dr’.,1.-:is. These resic· .. 1es ~·.ave: l:·eer. cx~,c~~<'. the elemer:ts fer several years. The \.later ccr:tei"'.: is esti:r.ate::'. about 15 - 35%. --- ?rocessin p. °? la:"'lt--- };:::zeJwo.a.d • .J:~i ssourJ. _ -·- ---·---- Tr1e ar;ilicant h.S (‘lf lE:::’. situ~. U·~
h s~uth St. Louis. This is an indt:strial zone. i.”n,;:r;; is ~ l2r;-·~
C:.5,0CJ(; squc.re feet) steel and concrete factory r:~1ilC.:’..:;;- ~;.::stil’f
aT this site. Th& applicants propose to adept ~his t0ildinf for
t’.ieir specific needs. 7:-,e final facility 1-;i.1..l ~un~:~st cf<'! r.>:.ir:
pr:::c.r:!”-c:in;::>, are?.• c:·,e::-5 ::.try laboratcry • cha’.’:,-·::: re·,’.”.:”.’. ~;;:! office: .-,~·f:;:;::.
/ ..
I. THE AIRPORT SITE
The. ComJDission maintains a 21.74 acre residue storage site adjacent
to the St. Louis, Missouri, municipal airport. The site lies
approximately 15 miles northwest of downtown St. Louis. It is
bounded by Brown Road to the North and East, the Wabash Railroad
main line on the South, and Coldwater Creek on the Yest (which is
also the property line of McDonnell Aircra~ Corporation). South
of the Wabash Railroad right-of-way lies Lambert-St. Louis Municipal
Airport and an area occupied by the McDonnell Aircraft Corporation.
Aircraft take-off and landing patterns cross the property. A location
map is attached as Exhibit 1. An aerial photograph, .Exhibjt 2.
locates the site with respect to adjoining property.
The site is completely fenced; there is a roadway access gate on the
North-side and a railroad gate on the South side, allowing ffabash
iailroad service to the pl.ant via a spur line off the main line
track. The complete area, with its mounds of raffinate residues,
stacks of drums, hodge-podge of. scrap alld temporary type structures,
has the appearance of a. typical spoil area common to chemical
indu~tries having residue storage ptoblems.
Consent to use and occupy the tract was obtained by the Manhattan
Engineer District on March 2, 1946. Title was acquired to the
property on January 3, 1947, by condemnation proceedings for
$20,000. The property was acquired for the purpose of storing
residues from the Destrehan Street Refinery and the Metals Plant.
The major capital improvements to the site were a concrete pit,
202 ft. x 42 ft. x 16 ft., constructed to store radium-bearing
residues (though it vas never used for this purpose), a covered
concrete pad 45 ft. x 250 ft. for the storage of drummed materials
and a railroad siding with loading tipple. A detailed description
of the structures on site is given a·s the last section of this
Exhibit.
The site vas operated by the Manhattan Engineer District and the
Commission from 1946 until J1.11y 1953, when the operation was
turned over to Mallinckrodt Chemical Works. Guards vere maintained
at the site from 1946 to 1951.
II. SOURCE OF iESIDfilS ON SITE
The Destrehan Refinery started operations in 1946, utiliiing
pitchblende ores and continued on this. feed until early in 1955.
– 1 …
EXHIBIT 5
………….. ·11
! ·:
;
.[
I . I
~. ……… -,–“‘·-·~·-·—-··—.-.- ..- ·–~·–…—-·~———~——-·—-·-·-·~ -~—— –~—-··· ….. i
The procurement contract for these ores with African ~tals
Corporation required the United States to store both the pitchblende
raffinate (AM-7), which contains metal values other than uranium,
such as nickel. cobalt, and copper, as vell as the radium-bearing
residues (K-65)t as African Metals retained ownership of all
material excepf .its uranium content. African Metals. subsequently
transferred ownership of the AM-7 raffinate to the Government.
A large concrete pit was constructed to store the radium-bearing
residue (K-65) but was not used for this purpose due to health
reasons. Instead, this residue was stored in druDlS at the site,.
from 1946 until early in 1948. It was then transferred to the Lake
Ontario Storage Area, Model City, Nev York, in 1948 and 1949. lhe
AK-7 was stored on the gro~d in the open where it remains today,
except for about 350 tons of pitchblende raffinate (AM-7) which were
processed in a small pilot plant facility at Destrehan Street to
recover ionium. This material was processed in 1955-1957 and
returned to the originf 1 raffinate storage at the site.
The raffinate (AM–10) produced from subsequent operations using nonpi1chblende
feeds was stored separately. A barium cake residue
(AJ-4) produced by the refinery is also stored at the site; this
residue resulted from the precipitation of digest liquor with barium
carbonate to reduce its sulphate content. Both of these materials
are stored on open ground.
I
The residues generated by the refinery aggregate to greater than
95% of the material present~ stored at the Airport Site.
The other major components of residues were generated as slag from
the reduction step of the metal operations at Destrehan Street.
Two types of this material have been generated. Initially the
reduction. bombs were lined with dolomite. The used dolomite liner
(C-liner) was shipped from Destrehan Street and stored at the Airport
Site in bulk on the ground. Shipments of the dolomite slag started
in March 1946 and continued until early in 1953 when the dolomite
liner was replaced by a recycle magnesium fluorine liner. Approximately
half of the C-liner has since been shipped to FllPC for
recovery of the uranium content.
In 1955 an Interim iesidue Plant was constructed at Destrehan Street
to scalp the uranium content from the magnesium fluoride slag produced
in the Metals Plant. tailings from this operation (C-701)
were stored in the concrete pit at the Airport Site, and since have
alt been shipped to FMPC for recovery or the contained uranium.
By 1960 there also had accumulated at the storage site approximately
50,000 empty drums and 3500 tons of contaminated steel and alloy
scrap. However, by 1962 the bulk oi these materials bad been disposed
of for the metal salvage values.
– 2 –
,,
‘ .
‘1
t
.r • t .
……….. -………. –·- —.–…·- … — …………….. ·-·—·
Approximately 2400 drums remain in the area; these c~ain aisc•l·
laneous residues, Japanese uranium-containing send and contaminated
scrap materials.
Haterbl presently stored at the site is stamnari.zed belcnn
Gross Tons Approx.Tons U
Pitchblende Raffinate (AX-7)
Raffi.nate (A.K-10)
Barium Cake (AJ-4)
Other Miscellaneous Residues
· and Captured Japanese 1J
Precipitates
C-liner slag
III. TOPOGRAPHY OF SITE
74,000
a2.soo
10.200
350
4,000
113
48
29
z
49
The original ground purchased in 1946 was Vf!ry uneven· and contained
• low drainage area on the western section of the site. The land had
a drainage slope from East to West, with all surface drainage directed
to the Coldwater Creek at the western edge of the property. The
initial topography of the site is shown in the aerial photograph,
Exhibit 6.
It has been extremely difficult to ;econstruct precisely the sequence
and location of contaminated materials and residues deposited on site.
The Committee has collected from various files and from McDonnell
Aircraft Corporation a series of aerial photographs which depict the
transition at the original site to its present state. Various reports,
drawings and sketches were also located which contributed to a general
understanding of the degree of contamination of the site. Numerous
individuals associated with the Airport Storage Site have been contacted;
however, since such a time has lapsed since the active
operation of the site, much or the information obtained by these
verbal inquiries is qualified by uncertainties of memory. .Also, many
of the people who were intimately associated with the site during
its early operation are no longer available.
Judging from the knowledge gleaned from the above sources, it appears
that with respect to the western part of the site, early dispositions
of contaminated scrap metal were located in the lov areas then existing
on the western end of the property. The scrap metal and other
debris were later covered (in 1952} with dirt received (gratis) Crom
McDonnell Aircraf’t Corporation and worked with heavy equipment to
make a level storage area (see Ex.hibit 7). The reclaimed area is
nov occupied by AM-10 raffinate, drums of Japanese sand and contaminated
rubble and other waste from Destrehan Street •
• 3.
.f ,,~
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. :· .’.
J”
~.
The existence or buried contaminated metal below the present surface
of the western section of the site was confirmed by tes,t drilling
described elsewhere in this report. Underground contaminated scrap
ia reported to be on the order of magnitude of 50 to 60 truckloads
plus one contaminated vehicle.
The eastern two-thirds of the site presently is covered with mounds
of C-li.ner slag, raffinate (AH-7)> and barium cake (AJ-4). These
mounds of residue rise to approximately 20 feet above normal ground
level. Drainage from the mounds and the adjoining areas is directed
to the Coldwater Creek •
.Drainage waters from the storage area have, in the past, produced
some minor contamination in Cold~ater Creek. Continued monitoring
of the complete area and the creek waters, however, has indicated
that significant levels have never been reached and that all radiation
readings are well within permissible and acceptable limits presently
prescribed by .AEC directives and manuals.
A topographic survey map of the site (Exhibit 3) shows the existing
limits of residue stockpiles, the general topography of the remaining
area on the basis of one root contour intervals and the location of
principal structures at the site. The aerial photograph, Rx:hibit 4,
shows the site essentially as it exists today.
IV. INVn.ITORY OF STRUCTURES
I
The area is iDclosed by a chain link fence. It c.ontains the folloving
structures1
A reinforced concrete pit consisting of floor slab and walls,
200 ft. long x 42 .ft. wide by 12 f’t. deep.
A storage shed consisting of a 250 ft. x 45 rt. concrete floor
pad, with a center wall 7 ft. high and 1 ~- thick running the
length of the structure. The pad is covered with a corrugated
metal roof supported on wood columns and trusses. Sides and
ends of the shed are open.
A single track railroad spur which enters the south fence near
the east end of the site.
A steel and wood· tipple is located along the spur.
A timber drum loading platform, 18! ft. x 8 f’t. x a!- ft. high,
with stone fill ramp, is located just east of the tipple.
A reinforced concrete wash pad for trucks, measuring 51! ft. x 3Si rt. is located east of the Storage Shed.
1 l
>
• • ) • •
– —·-~-~—– …. d d -·-·—_……._ -~- — ·-· ·—~—. ·-· ·-· .. ··-·—·-··—‘—-, I \C


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

Post
Post

1943-01-28 – Mallinckrodt – Staff Associated with Manhattan Project

REPOSITORY ;tiM d 112 Jf/}-‘(; f 4-tfol/t~J
l2 if- 3..2 6 – J.-.r-lf?.r- .
COLLECTION eu1uctL C-E/f/[jfl'{L /:’1 /e..f
BOXNo. /;+
FOLOER-‘4~%t”———-
2003800
ESTABLISHED 1867
MALLINCKRODT CHEMICAL WORKS
\ ;’ -.._._;
MANUFACTURERS OF
FINE CHEMICALS FOR MEDICINAL, PHOTOGRAPHIC
ANALYTICAL ANO INDUSTRIAL PURPOSES
. FA.CToAlES, ST. LOU1s:je:RSEv CITY, MONTREAL
SALES 0FFICE5′.ST. ,L..~UIS, NEW YORK, CHICAGO, PHILADELPHIA, MONTREAL, TO~ONTO
Colonel R. G. Marshal.1
The District Engineer
M•nhattan District
P. o. Box 42, Station F
New York, N. I.
Dear Colonel Marshalls
CABLE ADDRESSES
MALINKRODi, ST LOUIS
OESABRIDO, NEW YORK
CODES
A. B. C. FIFTH CO. IMP .
A. IJ C. SIX1″H E:O.
SENTLEV’S COMPLETE PH~ASE
BENTLE.V’S SEC.ONO PHRASE
Referring to your lett.er of January 6 relative to our.organi-
~ation chart~ I regret that in the press of other matters there ha.a been
some delay in replying.
In order to pr-osecute this project with the best possible
speed and at the same time maintain all possible· s.ecrecy > we have found
it necessary to organize a group who are responsible for thie project and
who do not necessarily function through usual channels of our cosps.ny
organization.· ·The following is a list or the personnel responsible for
the operation of this project, together with the particular function of
each.
Project leader, reeponsible for the administration
and over-all coordination of activities Mr. H .. v. Farr
Aesistant project leader, responsible for plant
construction and operation ~- L. s. Williama
Chemica.l. research and process development Dr. J. R. Lacher
Control and operation of Oxide Plant Dr. J. A. Kyger
Engineering Wld equipment design Dr. c. E. Winters
2003801 Procuremeni of materials and correspondence
coordination :itr. H. E. Thayer
Analytical Dr. c. R. Conard
… ,.., —;.-,-i Dr. A• ~. Butler ·—: -. A….._ _
–·—–~ . .._ …… ,,
\
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as foll<»•ec U. iaallir.clt:roat f"P 2003802 •.._..,._, / Mr. s. ~ .. • • n. ~r .. T .. ,. ( ( .>
~. Col&un
…. ti!,.. n”a:7eir
1’i~terG, Jr.

Post

1943-01-28 – Mallinckrodt – Receipt from War Department for Material from Canadian Radium and Uranium Corporation

,’, –
,~ R.noo. oo~. 11’1 ~
TELEPHONE: CIRCLE 6.0460
CANADIAN JUDIU~f & URANImf CORPORATION ORF 03540
SOLD TO
SHIPl.’ED_TO
TERMS
-and- ~_
EIDORADO-GOLD-MINJ!$-LDJlTEDWar
Department,
United States Engineer Ottioe,
MB.nhattan District • ~
P.O~ Box 42 .;; Station F.
New York, N.Y;
Mal1inckradt Chemioal Works,
~~P’O. Box·No. 8 – Bremen Station,
. St. Louis. Mo~
Net Cash VIA
ROCKEFELLER CENTER
630 FIFTH AVE., NEW YORK, N. Y.
DATE ~anuary 28, 1943.
Quantity . ~
::: DESCRIPTION Price Amount
=====I==T==I======~======================~~I===~===I~~==~
13,157.; Lbs.- -,Mc.::308
192
193
195
196
197
198<' Me l;l57,Jobs. 2' 00'0' .~ • 2;.QOQ 2.000 . 2;P00 2;000 2';000- 13;Wl'Lbs. 98 • .,% 98.7 get'~ 98.5 98.5 98.5 98.5 1 ~·9?O~ 1;9-70' 1;970' 1,.970 1;970<' 12; 9&7-Lbs.>
T-O;.,T”‘A-L
$ 1.895
..
.~. :
0’

Post

1974-05-16 – AEC – Investigation of Cotter Corporation Illegal Dumping at Latty Avenue

·’
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·’ UNITED STATES
.. … \
ATOMIC ENE:RGY· COMMISSIOr-.1
DIRECTORATE OF REGULATORY OPERATIONS 8~Tl720
. REGION Ill
799 ROOSEVELT ROAD
GLEN ELLYN, ILLINOIS 80137
MAY 1 1 1974
H. D. Thornburg, Chief, Field Support and Enforcement Branch
Directorate of Regulatory Operations, Headquarters
COTTER CORPORATION, GOLDEN, COLORADO
LICENSE NO. SUB-1022.(HAZELWOOD, MISSOURI SITE)
TELEPHONE
(312) $50.~660
Attached is a report of an inspection of subject licensee’s program which
we are forwarding for Headquarters enforcement.
During a routine inspection conducted on April 10, and April 23 and 24,
1974, at the licensee’s Hazelwood, Missouri, facility it was determined
that the licensee had disposed of approximately 8700 tons of leached
barium sulfate (Ba S04) which contained about 7 tons of natural uranium
(0.05 to 0.10%) to a land fill area near St. Louis. Missouri, as part of
their decommissioning of the Hazelwood site. The licensee representatives
stated that the uranium bearing residue had been mixed with approximately
5 times as much top soil, and therefore, in their opinion contained an
unlicensable percentage of uranium (less than 0.05%). The method used
for mixing was to spread the barium sulfate, which is a whitish, easily
distinguishable heavy compound,·over a considerable part of the 7 acre
Hazehrood site and then remove it along with approximately 12 to 18
inches of the surface soil. The purpose was twofold, to disperse and
dilute the uranium Ba S04 and to decontaminate the entire top surface
of the site which had be~n used for storage of uranium ore residues
since 1966.
The land fill area to which the material was disposed is one used by
St. I,ouis County \·lhich inc:!.1H:les the City cf St. Louis. ::::stit::

Post

1977-01-04 – NRC – IE Investigation Report No. 76-01 – 1976 NRC investigation of Cotter Corporation illegal dumping

ORAU TEAM
Dose Reconstruction
Project for NIOSH
NOTICE: If Privacy Act Data box is checked below, this information is protected by Privacy Act 5 USC
§552a; disclosure to any third party without written consent of the individual to whom the
information pertains is strictly prohibited.
Reviewers – complete all information that applies to the document, then place in front of the document.
Name fZ .
,.., .. ~
. ;
. . ~!.
Mn. Ca.rolyu »hfozd
~cto~, 1{1ssouri Uepart~c
of 5aturtU. r~aQU¥’~s
?.o. !los 1363
. .Je.ffer-..cc City, i10 6,5lDl
De&:’ MD. Aahfod2
JUN 10 1Sir
1.’bs. nfeft to • speeial inveatin~tion ecncucted by t..’lis of fic.e
t.o obt.aiD infocation -per…a~g to cbe ciicposal of nAtural
-ursa1-om on re.si.dues in :1 Sc. Lcuis County l:mcifill area by
‘dle catter Ccrpcrad.cm durins 197:3.. Tillie a.lGo refers to the
diseussioas held wit.b Ha.osns .. L v. Mlllcr en~ G. :!acUut;t of
the State elf !-‘…issoun. l!ureau af Tusc.i.ological. lie.al.th 1n
St. 1.cuis on Juna 6 &ad 7 • 1977 • at wb:ich ti!le a copy of ou1:’
:fnwstigaticm rBl)Ort WU furnisned to tbEQ. Althou~ thera
were u.o ites::s cf non~llmlc.a ,..”ith NRC re~ui:-£c:ents £.:nmd
during dUe i:rvestigat!.on, the i:RC believes that a more detailed
cviro~t4l. evaluation of these aite.a should be. conduc:ted.
Ia discussed vith He=-srs. 1-tUler ~mel !o’.acliutt, t!le i•uc.lettr
-J.egul.ator:y Comoisaicn has an:m~d for the 0~ lliC;e ‘1-i-tioual.
.. Laboratory to ~erfol::! 6Ucll e. suncy at: the S~. l.-ou;iS l:::nd.fill
aitca • u vell u at t.b~ property fol’t!l’erly occupied by tha
Cotte~ Coeyor.etion. You v.Ul be kep~ fully 1nfor.t~d of the
J:UUl.ts of that survey.
cc: Jarboe l’…C4lt? .m1d
h~at’men.t Cot:Jpany
Ja=ea c. ~pler
Dirac tor
Bau:folk .:md We.atem Railroad
c~ v/IE Icveatigaticn Report No. 76-01
j Cctter Corporatiml
C4mtrsl. Files
J.eproduct!lcm Utdt NRC 20b
PD’R
NSIC / …. I
(R’\l lJ,..’J ..’I !-;. ‘,/ .:…, !: 1.~ R·I”I. !’<•::'..' 1.-·/. j;'/.'i' - ..- . I : :...~,.;. ~ . . : ... • . .. ~---;r 1 ! -. __ ,_....;;; _____ _ No-reliu·s .-.-I~i? ler · · ·- i :!, -~ E:~~ 1! ; .. .·.· ,.. l ·' ·- .. UNITED STATES NUC-L·E·A R REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORC~NT REGION III IE Investigation Report No. 76-01 Subject: Cotter Corporation Ba%elvood, Missouri License No. SUB-1022 {Terminated) Allegations regarding the disposal of uranium ore residues vere partially substantiated. Period of Investigation! June 22-24, and August 11, 1976 . . l'lvestigaton:~ G. A. Phill i (6/22-2~76) ~ ~76 --~ Revieved By: W. B. Grant (6/22-24/76 and 8/11/76) tJ . A. 9 IZ~~u_~ ka_ A. G. J~uska . (8/11/76). /!"/) / . 0 1 u .. 'J{:-<":C-1.. t[, L-'/. •. Y . t. Jorgensen c:M:·i':l -1 .., , .{ ~!. · ·· - - •l l..'-L· G. T. Lonerga~. Chief Materials Radiological Protectlon Section _ .a.l?.~-t:A-'-·t·~· • • A. Pagliaro. Chief Environmental and Special Projects Section (10/20/76) [- '/-71 (Date) (Date) (Date) -~ \ ! i . ' : I n .... \ . - .. . .. i BEAsON FOR INVESTIGATION Following receipt of a letter dated June 2, 1976, from the Missouri Department of Natural Resources, forwarding newspaper articles contaiuiDg allegations regarding the disposal of uranium ore residues,• Region III initiated au investigation. SU'HMA.RY OF ~ACTS A report on f1 inspection conducted by Region III on April 10 and 21-24, 1974,- stated that according to licensee representatives the stockpile of the source material previously stored by Cotter Corporaeion under License No. SUB-1022 at 9200 Latty Avenue, Hazelwood, Missouri, bad been shipped to its facilities in Canon City, Colorado by m1d-1973 with the exception of 8700 tons of leache~ barium sulfate. The report further states: "Records tnaintained by Cotter Corporation showed that this material contained from 0.05% to 0.1% or approximately 7 tons of uranium as u3o8 • Licensee representatives stated, and records of invoices paid to B&K Construction Company show, that this material along with approximately 38,000 to 39,000 tons of soil removed from the top 12 to 18 inches of the Latty Avenue site was disposed of in St. Louis County sanitary landfill area No. 1 on Old Bridge Road over the period July 31 through October 12, 1973 ... The report. further states: ''This material vas hauled to the land-. fill area and used as cover for part of the several hundred truckloads of garbage and refuse that are shipped to the landfill area ·.site every -week. The licensee estimates that the barium sulfate is probably buried under 100 feet of garbage at this time. The trucks were hosed out: after hauling this material." Subsequently, on November 13, 1974, in response to a request from Cotter Corporation, License No. SUB-1022 was terminated. By letter dated June 2, 1976, the Director, DivisiGn of Environmental Qual~ty, Missouri Department of Natural Resources, sent copies of news articles appearing on May 30 and June 1, 1976 in the St. Louis Post~ispatch which indicated that the information in the inspection reporc was inaccurate. Specifically, the news articles indicated that: a) Only 9 tons of waste rather than nearly 40,000 tons of waste and soil had been moved from the Latty Avenue site. b) The material was dumped at West Lake Landfill rather than St. Louis County landfill No. 1. In his letter the Director, Division of Environmental Quality, stated that the depth at which the material was reportedly buried must be 11 RO Inspection Report No. 040-8035/74-01. - 2 - n. . ' ' ·. i iucor't'ect. since no St. Louis area landfills contained 100 feet ~ g l·l~ 12 ·g·.· fill. •. It was ascertained that: .. a. During the period.July 16 to October 9, 1973, over 43,000 tons of waste and soil were removed from the Latty Avenue site. b. The 43,000 tons of waste and soil were dumped at the West Lake Land£ ill. c. The material dumped at West Lake Landfill is covered by about 3 feet of other soil. The inaccurate information iu Inspection Report No. 040-8035/74-01 regarding the identification and location of the landfill area apparently resulted from miscommunication between the inspector and the B&K Construction Company representative. The erroneous information regarding the depth at which the residue was reportedly buried was based upon information furnished by th~ licensee who expressed this offhand opinion. Environmental samples were taken and beta-gamma surveys were made at the Latty Avenue and West. Lake Landfill sites on August 11, 1976. Tbe Latty Avenue site and environs was revisited on October 20. 1976, for additional environmental samples and alpha, beta-gamma direct surveys. The reporc for the O~tober 20. 1976 visit appears as At~achment D in this report. The Latty Avenue environmental samples confirm the removal of the bulk of materials but show that some residues remain. The Latty Avenue surveys showed radiation levels exceeding NRC criteria for decontamination of land areas prior to· return to unrest ric- ·-- ·- ··· ·· ted use. The West Lake Landfill surveys indicated that radioactive material is buried.there, and one environmental sample showed a slightly elevated natural uranium concentration. Based on the direct radiation surveys, neither site presents an immediate radiological health hazard to the public. For the environmental transport pathways evaluated, a hazard analysis indicates that the material disposed of at the West Lake Landfill does not pose any immediate hazard to the public presuming the presence of 1 tans of natural uranium. Solubility tests of the soil samples were not conducted, however, u3o8 combined with bariwn sulfate ··is known to be insoluble in water. Groundwater was not available for sampling at the West Lake Landfill site. A sediment and surface water sample was taken from a creek aear the Latty Avenue site. No items of noncompliance were identified during this investigatio~. 3 - ---~-- ,. . SCOPE OF INVESTIGATION . This investigation was conducted to determine the circumstances relating to the disposition of about 8700 tons of leached barium sulfate from the former licensee•s facility at Hazelwood, Missouri anq consisted of· a review of pertinent records, independent sampling and measurements and incerviews of individuals. CONCLUSIONS 1. About 8700 tons of leached barium sulfate containing abouc 7 tons of u3o8 were mixed with about 39,000 tons of soil at the Latty Avenue site as reported by the licensee during the April, 1974 inspection. The residue-soil mixture was transported to the West Lake Landfill area in St. Louis County where it is covered by approximately 3 feet of other soils instead of 100 feet as reported by the licensee during the April, 1974 inspection. 2. Environmental soil samples indicate the continuing presence of some uranium and thorium ore process residues at the Latty Avenue sitP.. Beta-gamma surveys performed by IE:III personnel at thae site on August ll and October 20. 1976, indicate levels o£ direct radiation exceeding the criteria established by NRC for decontamination of land areas prior to release for unrestricted use. Further~ these levels were found to be greater than those reported by the licensee in his application for termina~ion of the license dated May 10. 1974. 3. Based on direct radiation measurements of the material present at the West Lake Landfill and at the Latty Avenue site~ neither location presents an immediate direct radiation health hazard to the public. 4. It is estimated, using uniformly conservative assumptions, that the concentration of natural uranium in the West Lake Landfill could result in increased airborne concentrations of radon 222 and its progeny, directly over buried materials, of about onehalf of the 10 CFR 20 limits for unrestricted areas. 5. It is known that significant increases in indoor radon 222 concentrations can be experienced in dwellings built in or on disposed tailings. Physical and chemical differences between tailings materials, however. prohibit a direct comparison between what might occur in dwellings constructed in the West Lake Landfill as against the results of previous studies. A complete environmental impact analysis, specific to the materials at the landfill, should be performed to quantify the potential for radon buildup in dwellings built at the landfill. - 4 DE'I'AILS Introduction . . By letter dated June 2, 1976, Mr. Kenneth H. Karch, Direc:or, Division of Environmental Quality, lUssouri Department of Natural Resources, forwarded to Region III copies of articles published in the St. Louis Poet-Dispatch on l1.ay 30 and June 1, 1976 which he stated in his letteT 11 ••• 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 Commission subcontTactor removing radioactive waste material from a site in Hazelwood, Missouri." Mr. Karch stated in his letter that: "The investigation by the Pose-Dispatch indicates that AEC did not know tbe 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 contained 100 feet of. fill ... A copy of Mr. Karch's letter with news articles attached is attached to this report as Exhibit A • . BY letter dated June 17, 1976. Region III responded to Mr. Karch pointing out that Cotter Corporation, which ~as responsible for the burial, was au AEC licensee, not an AEC subcontractor and advising him, therefore, that the matter would he investigated by URC. A copy of Region III 1s letter is attached to this report as Exhibit B. Background In early 1966 the Continental ~lining and Milling Company, Chicago, Illinois, purchased from the Atomic Energy Commission ore residues which were stored at the St. Louis Airport. The material was moved from ·that site during 1966 to the 9200 tatty Avenue, Hazelwood, Missouri site. Continental Mining and Milling Company possessed License No. SMA-862 for this program. In January 1967 the Commercial Discount Corporation of Chicago, Illinois took physical possession of the. stockpile. License No. SMC-907 was issued to Commercial Discount Corporation on December 29, 1966 allowing possession of the residues, removal of moisture and shipment to the Cotter Corporation facilities in Canon City, Colorado. In December 1969 the remaining source material was sold to Cotter Corporation \Jho obtained License No. SUB-1022 dated December 31, 1969. The AEC's invitation to bid listed the following residues for purchase: 74,000 tons of Belgium Congo pitchblende raffinate containing about 113 tons of uranium; 32,500 tons of Colorado raffinate containing abou.~ 48 tons of uranium; and 8700 tons of leached barium sulfate coneaining about 7 tons of uranium. In August 1970, Cotter Corporation began drying and shipping the remaining residues from the St. Louis site to their mill in Canon City, Colorado at the rate of about 400 dry tons of material per day. This operation was performed for Cotter ~orporation by B&K Construction • S·- --I n --"''" ............. ... - ESll"129 . . Company and continued until about November 1970.- During the August to November period, all of the residues ~ere shi~ped to Canon City with the exception of approximately 10.000 t~ns 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 waa informed that during the period July-october 1973, the remaining Colorado raffinate was shipped to Canon City without dr.ying 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 containe·d from 0. OS% to 0.1% uranium as u3o8• Twelve (12) to eighteen (18) inches of the topsoil was stripped from cne Latty Avenue site and disposed of with the leached barium sulfate. Visit to Cotter Cornoration, 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 c·ity, 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. If 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 Corpora'tion 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 ~he site on more than one occasion in L973. 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 &aterial 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 .. .. •. ·r EJ S I' 112 9 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 Corporation, 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 rail 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 vas indicated that Mr. Warren Goff, who was avay 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 eost entries deleted. are attached to this report as Exhibit C. Visit to West Lake Landfill7 Bridgeton, Missouri On June 23, 1S76~ 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 lJlaterial being dumped and it looked like ordinar.y 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.. lle went on to say that the State required the~ to sink wells around the area so that samples of the groundwater could be obtained. He indicated that the State .. 7 - _ .. !'" ·. obtained and analyzed groundwace~ samples from repo~t any p~oblems regarding their findings. atill there. · e~lr729 the wells and did not He said the wells are Telephone Contacts with Ryckman 7 Edgerley, Tomlinson & Associates4 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 ~ere completed. During the first survey he made he found one small spot above 0.6 mR/hr. Re 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 be 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 - ... •. 8:=TI129 recorded: truck number, gross, tare. and net weights. A spot check vas 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 OD 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 ~ons. The invoices also show a total of 10,763.41 tons of material were shipped by rail to Canon 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 addi~ion ~o 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 s~atements, wi~h 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~" Billings were also reviewed ~hich had been received from the following: Bruce Barnes Truck Service, St. Louis; Vic Koepke Excavating and Grading Company, Bridgeton; and B. Reeder Hauling, Inc., St. Louis. On at lease some of these billings, there are entries sho~ing that material was hauled from 11Latty Avenue" or "Cotter11 t~ West Lake. It is concluded that the material in ques~ion 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 'lithin the intent of the Cotm:lission's 10 CFR 40 regulations (Exhibit E) concerning alteration of source material to ob~ain 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 ·. B2TI"729 The results of the August 11, 1976 surveys of the Latty Avenue site and the West Lake Landfill site with a narrative and reference Dateria~ are attached to this report as Attachment A. Results of the analyses of the environmental samples taken on Ausust 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 ~o 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 ~~imum gonadal or whole body dose would be: 0.06 mrad/hr X 8.76 x 103 hrs SOO 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 take 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 info~tion 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 mL~ture woul~ 7be 0.015 percent. With a natural uranium specific activity of 6.77 x 10 Ci/g, th!lo specific activit~4o£ 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 uC1/g for the two samples. - 10 - n .,. ·. r Calculations have been performed to estiln:ite radon-222 emanation fronB ~ Tl' 7 2 9 · the ground,_~ue 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 irom 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. Jith a dimension of forty meters. !his calculation yielded an approximate 0 atmose2eric d!spersion coefficient in the center of the area of l. 7 x 10 sec/m • · Applying this coefficient to the release rate of 0.1 uCi/sec_~ields ~n average increase in background air concentration of 1.7 x LO uCi/m directly over the covered tailings, which is about one-half of the 10 CFR 20 unrestricted area concentration limits. !his Rn-222 contribution in air, due to the buried materials, would be indistinguishable from back:round 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 Pathways Pathways oth.er 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 flunigative dusting can be discounted since the material is covered and not subject to becoming 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:!II 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 ~~posuTes 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 I ! ··-· .. ··--·-- of 7 ... ·. dwellings anc the uncertainties concerning certai~ parameters~feJ~j:729 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 buri.~d 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 0 06 6t 0 0 "' 0 0 06 6t 0 0 0 36 ft .... llm 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 • .... ---···. 36 ft ~ 11 -_ .. _. ----·---- .. m 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: 1 ... Attachments A, B, C and D 2. Exhibits A-E 3. References 1-4 12- n .,. Ss 1"1729 A'ITACHMENT A During a survey performed by this office on Augus t 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 ~y this office was noted . On May 10, 1974, Cotter reported exposure r a tes which ranged from 0.0~ to 0. 4 mR/hr measured at three feet above grade (type of instrument unknown). (Reference l) Thes~ values were the basis for · termination of the license by the .Directorate of Licensing. (Reference 2) The Reg'ion Ill 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 two areas reading 1.2 and 1.8 mrad/hr beta-gamma. The instrument used by IE:III inspectors in performing these measurements was an Eberltne E-500B vith an end-~ndow Mod-el HP-190 Hand Probe (1 . 4-2 mg/c.m ) • the presently acceptable limit for release of ground areas, as implied i.n the "Decontamination Guide" (Reference 4) is 0.4 mrad/h.r , total, or 0.2 mrad/hr. average, with a maximum of 1.0 mrad/hr~ all of 2 which a~e t o be measured at 1 em Yith a probe of not more t han 7 mg/ cm of total adsorber. Thus. the NRC Region III survey of August 11, 1976 showed r adiation levela at the Latty Avenue site -exceeding the acceptable release limits, while t he survey performed by Cotter Corporation showed levels within the guidelines. Both surveys indicate a low. nonba: ardous 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. ·... . .. '· • ATrAC:HHENT B ENVIRONMENTAL SAMPLE . Analytical Results by HSL Results (uCi/g) Sa11ple No . Sample· Description Natural Uranium L-1 ·L-2 L- 3 L-4 W-1 W-2 Soil Soil Ve~etation Wet Sediment From Cold Water Creek Soil Soil • 1.2 + 0.1 E-4 1.5 + 0.1 E-5 2.6 + 0.2 E-5 S.J + 0.4 E-6 5 + 2 E-7 5.3 + O.q E-6 ~ Note: 1) L-1 through L-4 collected at Latty Avenue Site 2) W-1, W-2 collected at West Lake Landfill 3) L-3 vegetation dried, analyzed dry, repor~ed as wet weight 4) · L-4 dried prior to analysis 5) A systemic error of + 20% should be assiRned to Ra-~26 analysis due to uncertainty of the equilibrium between Rn-222 and Rn-226. An 80% equilibrium ratio wae assumed. Ra-226 1.4 + 0 . 03 E-3 5.14 + 0.14 E-4 c - · ·- .. • . ' 't ATTACHMENT C Rn-222 Emanation Calcula.tions 1. Rn-222 a~ the Spoils/Cover Interface Toeal release g (area) 2 (source flux} ~ • (1600 m ) X DC 0 (~/(DS)) Assume: Kraner, et al, the natural Radiation Environment, 1964 D • 1.5 x 10-2 cm2/sec 1 x 10- 1 = lOA: 11emanation power" C • (1.0 nCi/g)(1.6 g/cm3)(1 x 10-1) 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-l s .. 0.25 0. 25 "" soil "voi4 fraction" total release= (1.6;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,-s,~ total release m 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 • a 1.5 x 10-2 cm2/sec A • 2.099. x 10-6 sec-l Z • 100 em sec: Tanner, The Natural Radiation Environment, 1964 C 2 •. (1.44 X 10-2) exp (-100 (2.099 X 10-6/1.5 X 10-l)~) • (1.44 x 10-2) exp (-1.18) • (1.44 X 10-2) (0.31) C 2 a 4.4 X 10-J pCi/cm2 • sec Entire area: (4.4 x 10-3) (1.6·-·x 107) ,.. 1.0 x 104 pCi/sec Therefore~ the total emanation rate is aboue 70 nC1/sec, or about 0.1 1JCi/sec. n. . ·. - 2- B3Tl729 3. Atmospheric Dispersion Coefficient •. X/Q • 1/woyazu a and a are calculated using the "virtual poinc: source" method d~scribea in Workbook of Atmospheric Dispersion Estimates, as follows: a. for a square area with 40m sides, oyo • S/4.3 a 40/4.3 • 9.3m b. in the area, a = a a 9.3m yo Y e. at 20m (center of area from side), stability class E, and ground-level release, o = lm z 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)(1.7 x 10-2 sec/m3) ~ 1.7 x 10-3 uCi/m3 • n . . .. .•· ·~ .. . - f INVESTIGNrtO:·~ FOR URAN!l.fl-t/TlTORIUH ·e2ll.129 . COTTER CORPOrv\TlON, LATTY AVENUE ~Irr:, ST. LOUIS, MISSOURI QCTOnER 202 1976 'Pursuant to the oncoins investigation of pot::sible uranium/thorium contamination at the LD.tty Avi!nue site, He~;:a :.; • J'. A. r:lt•.liaro and G. T. Gibson.. performed n site inspection on Octoher 20, 1976. The pu~·posc of this irJspection wa!i to identify the propc1:ty owner from ·county tax rccor.ds, to surv~y the prnpc:r.ty with b<:tiscouT.t
CoTporation had tr.nium isotopes but not t horium and thorium daugh tc~ rs.
The “warehouse dirt” sample s ho\oled_ 0. 3 toR/hr bc t a-cnmm.::l and 26,000 DPH
alpha at conttlct l..’ith .::1 sample of about 250 C· G.onuna sc::tnning ‘o~ith
Nal indic01ted both uraniUlll and t:horium and t heir de:cay chain produ.::t:s
to uc prc:;cnt..
.•


. ·-
..
– 3- .,
·.
The results of alph~ spectroscopic an~lyses of tho two soil s~mples by •
HSL are presented in Table I .below. HSL nn.:1lyr.cs of .the two soybc::m
samples showed only small quantities of naturally-occurring K-40 •
. . .. TABLE I
Alpha Spectroscopic
Sample RadionuclidC! Concentration (uCi/~)
‘rh-230 +
0.05 E-02 I 3.61 Th-227 4.4 + 0.2 E-04
U-238 6.64 + 0.06 E … 04
U-234 6.52 + 0.06 E-04
U-235 3.09 + 0.07 E-05
Ra-226 5.2 – 0.1 E-Olt
‘Warehouse Dirt ·
U-238 0.3 + + 0.1 U-234 0.3 + 0.1
U-235. 0.3 – 0.1 £-02
Yellow Haterial
_; ..
. ..
. ·
.. .
… -· . ..
• ..
~
A~~~ ,•,.l.r.l\i’.1
tk·r~
;
•• > …
_ _._
~ ~ ·1· ·r· 7 2 .• .::.j … 9~
•.
J
:
i
I
i : I.:
: I
l i t
:. a . I : . . I : I l
~ : ‘ . ! :
f ~ : t

! i
i ; I
: . ‘ i i : . I
: I
I I ; ; ‘!
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Search Document Archive

Navigating the Archives

The archives can be accessed here.

To make a detailed query of the text of every document in the Archives, use the search bar at the top of the screen

The file names for each record include up to three components:

  1. the date of publication;
  2. the acronym of the agency or organization involved (if applicable);
  3. and the subject matter of the record.

Search Queries:

To search for any record that contains one or more words in the body of the document, put those search terms in the search bar. A search query with two or more search terms (ie: Fukushima Daiichi) will return all records that include ANY of the terms entered(Fukushima AND Daiichi), even if they are not found consecutively in the document.

To search for specific strings of two or more search terms(ie: Fukushima Daiichi ), while excluding records that include separate references to each search term, place the search query in quotations "Fukushima Daiichi" in the search bar.

Document Collections

Records are grouped together into the following collections:

  1. Collections by Agency
  2. Collections by Organization
  3. Collections by Event
  4. Collections by Site