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UNITED STATES NUCLEAR REGULATORY COMMISSIONOFFICE.,OF; I.NSPECTION AND ENFORCEMENT '-..-7,

F-REGION.Ill'

IE Investigation Report. No !76-01

14

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V.-

V.A.

Subject:F'o

Cotter Corporation•.Hazelwood, Missouri

License No.'4SUB-1022 (Terminated).3:

Allegations rega'rding the disposal of uranium-ore residues were partially substantiated.-

-" -a . .. ...- :F• • ," . 7 • . .- .

I o,Period of Investigation: June 22-24, and August I

__ ..... nv,,esti _ators ts,G. A. Phillip/

S: -,., (6122-24,F76)

.i B., Grant. '-•(6/22-24/76 and 8/11/76)

."-A. G. J uskaT'i!'21' I I'A•

.,, 1976

E (Date)

,L". Jorgensen -'

, ...

Reviewed By.,

I:

G. T., Lonerigaq, Chief- Materials Radiological

. rdo.ectie n Sect.on

(- -ate(Date)

(Datce)' (Date)

(Date)

(Dyate)'.' "• !!". , %A, Pagliaro, Chief.. nviibnental and SpecialProj.ects Section

(10/20/76)

• .• ,, . : .-7

8606040407 860530PDR FOIA.BARNES86-117 PDR .1*, 2.

.1 _________________________

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Coa, .REASON FOR INVESTIGATION

Following receipt of a letter dated June 2, 1976, from the Missouri,Department, of:Natuhral Resource -,.. forwardi t newspaper articles con-taining allegations regarding the disposal of uranium ore residues,'Region III initiated an investigation.

SUK•MARY OF FACTS

A report on p inspection conducted by Region III on April 10 and21-24, 1974,- stated that according to licensee representatives thestockpile of the source material previously stored by Cotter Cor-pora.tio.n under License No. SUB-1022. at 9200 Latty Avenue, .Hazelwood,,Missouri, had been s.,.ipped to its. facilities in Canon City, Colorado . •by mld-1973 with the exception of 8700 to-.s of leached barium sulfate.The report further states: "Records maintained by Cotter Corporationshowed that this material contained from 0.05% to 0.1% or approxi-mately 7 tons of uranium. as U 08. Licensee representatives stated,and records of invoicjes patid o 8 B&K Construction Company show, thatthis material along with approximately 38,00Q to 39,000 tons of soilremoved from the top ,i" . 18 ipches of the Latty Avenue site wasdisposed of in St. Lou.s .opunty sanitary landfill area No. 1 onOld Bridge Road.over..the period July 31 through October 1.2, 1973."The report further states: "This material was -hauled to the land-fill area and used as cover for part of the several hundredtruckloads of garbage and refuse that are shipped it the landfill areasite every week... The licensee estimates that the barium sulfateis probably buried under 100 feet of garbage at this time. Thetrucks were hosed but after hauling this material.".

Subsequently, on November 13, 1974, in response to a request fromCotter Corporation, Licen~ie No.'SUB-1022 was termina~teA.

By letter dated June 2,, 1976, the Director, Division of EnvironmentalQuality, Missouri Department of NaturaV' Resources. sent copies ofnews articles appearing onMay 30 and June'l, 19476 in the St. LouisPost-Dispatch which indicated that the-Tformation in the inspectionreport was imaccurate. Sp'ecifically, thle news articles indicatedthat:

a) Only 9 tons of wastrtejather. than ii-irily 40,000 tons of wasteand soil had been,,moyved from the Latty Avenue site.

b) The material was dump'ed at West Lake Landfill rather thanSt. Louis County landfill No. 1.

In his letter the Director, Division of Environmental Quality, statedthat the depth at which the material was. reportedly buried must be .-

1/ RD Inspection Report No. 040-8035/74-01.

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incorre'tJrsince1Lno St. L'uis 'area lqpdfills.:•o10t.aine. 0 J0f et.,f.fill.h t:C• t) t• .::, .

a. During the "period July 16 to October 9, 1973, over 43,000tons of waste and-soil were removed from the Latty Avenuesite.

b. The 43,000 tons of waste and soil were dumped at the WestLake Landfill.

c. The material dumped at-West Lake Landfill is covered by• . about' 3 feet of ocher soil.-.'

The Anaccurate info'a t-ion~in Inspectioh Reý,qi No. 040-80351/74-01

regaTding the idehtification and location o6?th'e landfill area appar-

ently resulted from miscommunicatio'n' beýtween the inspector and theB&K Construction Company representative.. The erroneous informationregarding the depth at which the residu'e-was..reportedly buried wasbased upon information furnished by th, licensee who expressed thisoffhand opinion. - -"

Environmental samples.were taken and beta-gamma surveý,s'were madeat the Lacty Avenue and West Lake Landfill sites on August 11, 1976.The Latty Avenue site and environs was revisit•d on October 20, 1976,for additional environmental samples and alpha, beta-gcia directsurveys. The report for the October ,20, 1976visit appears asAttachment D in this report. The Latty Avenue'environmental samplesconfirm the removal ofthe budlk of materials' bdc shod that some residuesremain. The Latty Avepue surveys showed radiation.levels exceeding NRCcriteria for decontamination of land areas 'prior to.return to unrestric-ted use. The West Lake Landfill surveys indicated thaC •radioactivematerial is buried there, andone environmental sample showed a slightlyelevated natural uianium'concentration. Based on 'he direct radiationsurveys, neither sit'e presents an immediate radiological health hazardto the public. ,

For the envir9nmental transport pathways evaluated, a hazard analysisindicates that the material disposed of at the West Lake Landfill doesnot pose any immediate hazard to the~public :presuming the presence of7 tons of natural uranium. .

Solubility tests of the soil samples-were not conductedi however,U308 combined with barium sulfate is known to be insoluble in water.Groundwater was not available.,for sampling at the West,.Lake Landfillsite. A sediment and surfacew.ater sample-was taken from a creeknear the Latty Avenue'site. ,.

No items of noncompliance were identified during this investigation.

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. to ,' ..SCOPE.. OF INVESTIGATION , .

This investigation was conducted to determine the circumstances relatingto the disposition of about 8700 tons of leached barium sulfate fromthe former licensee's facility at Hazelwood, Missouri and, consisted ofa review of pertinent records, independent sampling and measurementsand interviews of individuals. t -.

CONCLUSIONS

1. About 8700 tons of leached barium sulfate containing about 7 tonsof U 308 were mixed wilth about 39,000 tons of soil at the LattyAvenue site as rleported by the licensee.d!#ring the April, 1974inspection. The residue-soil mixture was transported to theWest_ Lake Landfill area in .St. Louis County where it is.-coveredby approximately 3 feet of other soils instead of 100 -feet asreported by the l'.ice'nsee-during •.the April, 1974 inspection.

2. Environmental soil samples'.indicate the continuing presence ofsome uranium and thorium ore process residues at the Latty Avenuesite. Beta-gamma surveys performed by IE:III personnel at thatsite on August'.11 And October.20, 1976, indicate levd•§ of direct

•. radiation excteding"the criteria established by NRC for decon-tamination of land areas prior to release for unrestricted use..,.Further, these levels were.found".to be greater thinthose repor.tedby the licensee in his application for termination-of the licenisedated May 10, .1974.- c. - ' •: - .

3. Based on direct radiation' measuiýements of the mai6ria'present,at the West Lake Lindfill afhd, ai the Latty Avenue"irt6, neitherlocation presents an immediate direct radiation health hazard o,,-to the public.. i .

4. :.It is estimated, using uniformly conservative ass .aitions, that-t Che 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 one-. t,.,.--.half of the 10 CFR 20 limits for unrestricted areas. ...'

5. It is known that significant ;increases in indoor'radon 222 concen-trations can be experienced in dwellingilbdilt ifior on disposeda"

L tailings.' Physical and chemical differences between tailings ,..materials, h6wever, prohibit a direct cbdparison between whatm. might occur in:d.fellings constructed in'-'ho"Weist Lake Landfill 'as

,' against the results of previous studies '" c environmentalimpact analysis, specific to the materials at the landfill, shouldbe performed to quantify the, potential for radon buildup in dwell-

1.' Ings built at the landfill. .. ...

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"c iat ir.,DETAILS c'ryidi . th;

* ut. 440`J d r . ~Introduction, -:, . o. r zoria by"

By letter dated Junre 2, 176, Mr. Kenneth M. .Karch, Director, Divisionof Environmental Quality, Missouri Departmednt of Natural Resources,forwarded to Region•III copies of articles'published in the St. LouisPost-Dispatch on May 30 and"June 1, 1976 which he stated in his letterit... presented evidence that some seven tons of uranium were dumpedin 1973 at the West Lake Landfill in St. Louis County by an AtomicEnergy Commission subcontractor removing radioactive waste material froma site in Hazelwood, Missouri." Mr. Karch stared in his letter that:"The investigation by the Post-Dispatch indicates that AEC did not knowthe correct location of the dumping, the .local geology, nor the actualconcentration of urninum-dumped. 'The dept~h:bited must also be incorrectsince no landfills..ihthe7'.St. Louis area contained 100 feet of 'fill."A copy of Mr. Karch's litter with news article.s attached is attached tothis report as Exhibit A.-

By letter dated June 17', 1976, Region III responded to Mr. Karch pointingOut that Cotter Corp~d;altion, which was responsible for the burial, wasan AEC licensee,".not"11'a-EC subcontractor and advising him, therefore,that the matter wouldi'bi investigated by NRC. A copy of Region III'sletter is attached i6lthi report as Exhibit B.

;m .: . 3- ":':, . : .) .Background -j• •I•. :.• ; ': ' (•. . -:• .... ... .:

'In early 1966 the Contihnetal Mining and Milling Company;' Chicago,Illinois, purchasid' from the Atomic Energy Commission' ore residues .ewhich were stored at7 the St. Louis Airport. .-.< The materia~lwas'movedfrom that Site during -1966 to the 9200 Lariy Avenue, Hazelwood, Missburisite. Continental Mining".and Milling Company possessed ficeni' No.SIHA-862 for this progiam."' In January 1967Y he Commercial- Discount -.Corporatioii of Chicago,'Ill-inois took physical possession of thestockpile. License N4. SM4-907 was issued io' CommercialfDiscount •eCorporation on Decemb'6r"'29'ý 1966 allowing possession of the residues,removal of moisture and shipment to the Cottet Corporati'on facilities!! in Canon City, Colorado. "In Decembir 1969"•th remainini)'source materialin' Cao.

mawas sold to Cotter' Co'rporation who obtained License No'. SUB-1022 datedDecember 31, 1969. 'The AEC's invitation to bid listed the followingresidues for purchasie: 74,000 tons of Belgium Congo pitchblenderaffinate containing about 113 tons of uranidm; 32,500 tons of',".,

4Colorado raffiriate contaihing about 48 to s'"f urani.a; and 8700 tonsof leached barium sulfate'obntaining about 7 tons of uranium*,1 , . 4' • • • , . . . .' : : :

In August 1970. Cotter Coi'koration began'dr)ing and shipping tii :-remaining residue; from lthe St. Louis siteitl their mill in Ca:no'n City,.Colorado at the rat'e of about 400 dry tons of material per day.This operation-was .p.rrformed for Cotter Cor'poration by B&K Construct'On

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Company and conrinued anti•.Jabout November 1970ý During-.the.Augustto November period, all ".'3f4t-he residues were-shipped,:to C.nonv City w4ththe exception ofirapproximately 10,000 tons ofi.Colorad6 raffinate -and8700 tons of leached bar-i•mt-sulfate. 'There was no further activityat the Latty Avenue site until mid-1973.

During an inspection conducted in April 1974, a Region IlI inspectorwas informed that during the period July-October 1973, the remainingColorado raffinate was shipped toCanon City without drying and theleached barium sulfhate along with 38,000 to 39,000 tons of soil hadbeen disposed of in+a landfill area.in St. Louis County. The leachedbarium sulfate contained from 0.05% to 0.1Z uranium as U 0 Twelve (12)to eighteen (18) in'ches of the topsoil was stripped from3 te Latty Avenuesite and disposed olf withit-he leached barium sulfate.,.,

Visit to Cotter Corporat on, Lakewoo'd, 'Coloado

On June 22, 1976, the following information was obtained during a visitto the Cotter Corporation, Lakewood,' Colorado office-'. Mr. David P.Marcott, Executiye Vice President Qf Cotter Corporation, stated thatall of the source material once stockpiled at the Larry Avenue site had

been shipped by.rail Jts facility in Canon Ciy, C9lorado, except*theapproximate 8700 tons of leached barium sulfate." The material had vey'low concentrations of uranium, from 0.05% to 0.1%, and it was consideredcommercially impractical to further process this' material to remove ?.the uranium. He.indicated .that it. would be necessary to process thematerial with. several hfindrid pounds ,of hydrochloric acid to leach apound of uranium from each ton of the barium sulfate. If the uraniumcould be leached out uji.g water the licensee would certainly haveprocessed the 'materi-'al ather than disposing of.- it. He- indicated thatcfor this reason he was confident tthat the 6uraniuj'iremaining in the .leached barium sulfate now located .in a landfid- would not leach OUt,'

into the groundwater. .,He said that ..the average uranium content of orecurrently being process.ed by the mining industrylwas 0.16% which isgreater than that disposed of in the St. Louis area.' He indicated thatsome ore being processed by Cotter Corporation contains 0.65% uranium.He indicated that in his,,opinion the uranium contained in- the leachedbarium sulfate did not ,constitute any threat.tor the environmentwherever it is now located. u .

Marcott further advised- that he visited th " site on more than -oneoccasion in 1973.. lie inidicated thaý on one occasion Mr. Robert Davisof B&K Construction Company drove him around theearea and pqinted ou•,to him the landfill area where the.material 'wouLd be'dumped. He saidhe 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 onthis basis that he- had expressed the opinion that 'the material wasprobably buried under 100 feet of soil and. garbage. -He indicated tha' " --

he also visited the .,Latty Avenue site on anothe~r~ occasion and personally.saw the trucks removing the dirt from the premises.

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;Marcott stated :that B&K supplied.weight sheesnalouig'with-the invoices.submitted for payment. forndisposi:ngi of the bavium sulfate and dirt'.from the LattyiAvenue" site.. These invoicestal-o'included-tharges for"the Colorado-raffinaie shi-pped by.rail to Oanaf".City during the same-period of time.' k - ... '-.': ' ar.' .

Mr. Duane A. Dughman',I Vice President-Finance of Cotter Corporation,provided copies of 11 invoices for the period July to October 1973.These invoices showed a to~tal of 48,544.70 tons of material were truckedto a disposal site which is not identified on the invoices. The invoicesalso showed that 10,763.41 tons-of material were shipped by rail duringthe same -period. C .

Dughman stated that he had`.'.reviewed all related records in Cotter's filesand none of them identified ,the.landfill area, to which B&K Constructionhad taken the material. Dughman stated that the only papers relatingto the Latty Avenue site n6t ccntained in the'master.files in the-Lakewood, Colorado offices were the weight shee'ts that had accofpaniedB&K's invoices. He indicated that these had been retained at the CanonCity facility. He made an..inquiiy by telephone of personnel at' theCanon City facility concerning the wei,.ht sheets and was advised thatthey couldn't be located.) It was indicated that Mr. Warren Goff, who was2.,

away and not scheduledO to return for several days, was the only' one .hwho could locate them. '.

Copies of the 11 invo'iceswere abtained and copies of them, with the

cost entries deleted, are attached to this report as Exhibit C. ..

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Visit to West Lake Landf , Brid~eton, Missduri-

On June 23, 1976, the following information was obtained from Mr. Vernon!

Fehr, Superintendent of Plant No• I West Lake Landfill'.. .-

Fehr indicated that be recalled that about three years ago, B&K` .

Construction Company had *iumped ihat.he understood to. be clean fill inan area adjacent to the-o'fice bt~iiding. He indicated, that he had seenthe material being dm•mped:.nd it'looked like&ordinary dirt'to him,.-

Since clean landfill i-s useful as" cover, there is no charge for 'dumpingit and no records.are.'maintained.of its receipt. It was his recbllection,that the dumping of the" materialrdid not ivol•ve any formal arr'hgement,.The truck drivers just•camie to the site and"he told them'w.here to dumpit. He stated that he',could identify the specific, location where thematerial was dumped and. estima:ed that it wa-s, three feet down. 'While ,:

he recalled that a, large quantity of material was. dumped, he was some-what doubtful that iti totalled 39,000 tons.' -.1!

Fehr advised tha't in 19'74 the'Missouri Department of Natural Resourcesadvised West Lake'to discontinue dumping in Wo areas on the site,.one of those being the area where the B&K material was located. Heindicated t ha.-this aroawas full anyway. Jlle went on to-say that.theState required them to-si.nk wells around the area so that samples ofthe groundwater could be obtained. He indicated that the State .

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obtained and .analy.-ed'groundwaiter samples-,ftom thewell.s and. did ngtreport any problemis regardingttheirdfindings•.. He ,said the wells arestill.there." ." -' " f ý..- ' c <. ' 5•ed

Telephone Contactsiwith RyckmanA n Edgerle•;, romlinson & Associates, rSt., Louis Missouri I ,. .hc ' t . I- - : is

On June 23, 1976, 'telephone contacts were made with Dr. E. Edgerleyand with Mr. Phillip K. Feeney of Ryckman, Edgerley, Tomlinson &Associates, an enyironmental engineering firm that provided consultantservices to Cotter'Corporati h on health physics and site decontamina-tion. ..

Dr. Edgerley stated that while he had visited the Cotter CorporationLaity Avenue site:when the residues were-;being dryed and._shipped toCanon City, Colorado, he had no personal knowledge concerning thedisposal of 'the material remaining onslte after these 6perations werediscontinued.

Mr. Feeney stated that he was aware that Ehe topsoil was stiýpped from

the Latty Avenue site'and trucked to a laildfill but he did not know whichone. He indicated that arrangements regarding the disposal operationswere made directly between.Cotter Corporation and B&K ConstructionCompany. Feeney stated that he visited t~hdesite to perform:a terminationsurvey after being informea that 'the dis psal operation's were completed.During the first'survey he•.imade,:he found oz'small s-pot above 0.66 `mR/hr..."~ýý thi Ar " -oI; .. • . • 'hi h . . ", "' di at,

He instructed B&K to remove some dirt from this area which he indicatedwould be a truckloaaior legs. Subsequenfly, •he returned to the site andfound less chan' O.l"mR/hr." 'By litter dat'ed 'May, 1974, the results of•:: Feeney's survey were furnished, t' Cotte'r4Co'porati6n.'AcOpy.of thisletter with its'iat-achments appears as Exfi'bit D in ihis report.

Visit to B&K Cori's tuiction Compan ', St. ,Kn ,..issoui .

On June 24, 1976, Mr. Robert S. Davis, Vice President, B&K Construc-tion wompany, as' interviewed. uavis sta'ed'that the amount"

' of material shown on the invoices submittea to -otter Corporation was

disposed of by trucking to the West Lake Landfill during the period"July 16 to October 9, 1973 wiith ihe exc 6eip n of 5,000 tons. He indicatedthat this 5,000 tons represented topsoil stockpiled in one corner ofthe Latty Avenue site. He "had removed itaiiid then returned it to 'thesite after disposal operations weie completed. This topsoil along withother topsoil was used to.dress the site. He felt that he should be:.paid for handling theýý.sto''kpiled-'topsoil, and "that the 5.'000 tons wai

•:included in the aimo'unts' on"'the in"voices ýie~n"Ito, Cotte'r Corpo~altion. "

Davis was no chargfor dumping the materialat West Lake, he had arranged to have thedrndividual operating the scalesthere to record the weights of each truck on sheets-of paper. Heindicated, .

he was required bytiCoiterACorporation to .submit these weight sheets withthe invoices. Davjs provided copies of the weight sheets which bearthe heading "B&K D.irt Hauling" and the date; The following 'information is

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recorded: truck ndmber, gross, tare;. *ndi t''weights. A spot che..was 'made of the., to:t;ll of the net weights'ishcwn on the'sheets as -wellas the totals of. the!inet weights forta bilit.ig period with the weighjtson the.coveringinvo'ice. No:..discrepancies.l'wre found. There were atotal of 104 weight sheets associated with these invoices. The totalweight of material trucked to the disposal area shown on the invoiceswas 48,544.70 tons. Subtracting the 5,000't'ons of topsoil referred toabove, the amount of material trucked to th'ý disposal area was 43,544.70tons. The invoices also show a totaýl of 10,763.41 tons of material wereshipped by rail to:Canon City.

Although the above invoices and weight sheets did not indicate thedisposal area to which the material was taken,.Davis stated that itwas .taken to the West Lake Landfill.'"He.of-fered for review a job cardrecord relating to the Latty Avenue site and several entries were notedfor the period July,16, 1973 to October 10, 1.973 which indicated.residue was taken to West Lak foCtterLt yAvn.

• ' Lake f rom Co.tt, La'tty Avenue'. " ~

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Davis also stated that in addition to:using his own trucks, he arrangedfor much of the hau'ling to be' done byoth" rtruckini 'firms. "e madeavailable for review from his records, bills from these firms. Weeklybilling statemen~ts, ,with .drivers.time tickets attached, covering theperiod August 3, 19-73 to October 12, 1973' were noted from Walker,Trucking Service, Ferguson, Missouri. Thesie billing statements containthe notation ILatty' Avenue to West Lake." Billings were also, re'viewedwhich had been received from the following': 5B'ruce Barnes Truck Service,St. Louis; Vic Koepke E.xcavating and Grading Company, Bridgeton; andH. Reeder Hauling, Inc., St. Louis. On at least some of these billings,there are entrie's s.ho6wing that material was hauled ftom InLaty Atenue"

or."Cotter" to.West Lake. :. .' *.. . . , 2' . . i " . . " ' ' ' • • " ;

It is concluded that the material in question is now buried under_about three feetjof clean soil at the We'stL Lake Landfill. WhileZl.ittle,significance was attached to the .actuial location of the disposed ... ' a.

material at the time 'of the 1974 inspection,>the licensee was no.-,fi d by J t ' , '''! "P. , :

fied, by letter dated November 1, 1974, tat' the disposal did not appearto be within .the intent of the o CFR 40 regulations.

(Exhibit E) concerning alteration of source material to obtain a.-mixtureno longer subject t.6.licensi .ng- .,

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Visit to Latty Avenue, Hazelwoodj, Missouri Site and West Lake Landfill.Bridgeton, Missouri Site . - .- .. ...... .. . . .

On August 11, 1976,."wo Inspectiqn and Enforcement Region III inspectorsvisited the Latty Avenue site and West Lake' andfill site for the purposesof performing radiation surve 'and citdlec ting environmental samples.The Region III inspectors were_,'#compniedby .Mr Stephen Nagle to t'he

Latty Avenue site and Mr. Clarence Stein tIo the West Lake Landfill site.Messrs. Nagle and Stein representgid the State of, is'ourL. Dvision .of. -

Environmental Quality, Department of Natural Resources. -:j

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th 0 Avnu Iit andMThe'results oY the August 11, 1976 surveys.of 'he-Latty Avenue'ite and

ehe'West Lake Landfill iite with a narrative and reference material areattached to this report as Attachment A.

Results of the analyses of the environmental samples taken on August 11,1976 from.the-Latty Avenue site and West Lake Landfill site are attached tothis report as Attachmernt B.

Measurements performed at the West Lake Landfill and analyses of samplesfrom the area have been reviewed. The following hazard analysis is basedon the measurements and analyses and on information derived from per-sonnel of the former licensee.

Direct Radiation - West Lake Landfill '

$eta- gana.,,jsurements rade..at three. feet frot&-,-e surface ind-i-cate two -

general areas where readings' bove background Ler.inoted. These measure-

ments indicated 0.06 mrad/hr '6iaxium.. The measuriements at' contactindicated 0.8 mrad/hr maximum, and about 0.1 mrad/hr average. Thus, forcontinuous exposure the maximCr gonadal or whole bddy dose would be:

0.06 mrad/hr.. X 8.76, x 0 h 500 millirads/year or approximately

500 millirems/year. year

However, the area has been closed for dumping by Missouri DINR and isessentially unoccupied. _], . ,. ..

Calculated Atmospheric Concentrations of Rn-222. at West Lake Landfill

West Lake Landfill area.sample analytical results do not i.ndicate thepresence..Of significant•,'natural uranium activity. These. surface samples,however, would not be expected to be representative of, material whichis reportedly covered by. overburden with a thickness of approximatelyone meter. ',. " . .. i-

According to. information iprovided by the licensee, the covered materialconsists of approximately 7 tons of natural uranium in about 8,700 tonsof barium sulfate and about 39,000 tons of soil. Thus, an approximatenatural uranium weight percentage of the mixture .would be 0.015 percent.With a natural uranium specific activity of 6.77 x 10 Ci/g, the 10specific activitZdof the 7mixture would be approximately 1.0 x 10

Ci/g or 1.,0 x 10 uCi/g. 'Analysis of two surface samples from the LattyAvenue site (source .of the covered-material) indi ated naturaluranium concentrations of approximately 1.0 x 10 .-,IuCi/g, which supports.this estimate of average mixture Leoncentration. T".• Ra-226 analysis.showed an average concentration of about 1.0 x 10 uCi/g for the twosamples.

1 "t, k.. . "

S,.i ,! ., ..

"I. ... ., ..

I..

t

-I -

a *

' • " . ' -. ; ' : g.'O , .1 u• . .i.. ck... . .

Calculations have been -p'etformedl to estimatie..r-adon-222•;emanacion fromthe ground, jue to bdried'.material with an average Ra-226Cdoncencrationof 1.0 x 101 .:UG4i'~gvbelow a Idepthý of:: 100 cm. ;.,.These calculation:; indi-Cate a totali.release.-.of' approximately; 0.1 uCi/sec.of radon-222 from theground due:tctzthe: covered,,tailings mixture. .It. should be;noted thitthe tassumedi.depth ofoburial yields .a.reduction of about.a~factor ofthree 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 ,ira was estimated to be'approximately square,, with a dimension .of forty meters. This calculation yielded an approximate

- atmos2 eric dispersion coefficient in the center 6f the area of*"' L.7 x 10 sec/mn . * . - . .

1-4'U4. Applying thisoe--oefficient to the .release rate of 0.1 uCi/sec_3ields ;naverage increase in background 'air concentration of 1.7 x 10 uCi/m•

. directly over. the covered tailings, whiLch is about 'ohe-half Vf theL. 10 CFR 20. unrestricted area concentrat-ion limits. This Rn-222 contribu-

tion in air, due to the buried materials, would-be' indistinguishablefrom backround within a few hundred meters from the landfill. Basedon the conservatism of assumptions, this atmospheric concentration ofRn-222 is considered an, up per limit. "Calculations are appended to thisreport as Attachment C.

!. . Other Pathways •. .. , ,_c; .• •' •• .

.n4 Pathways other than direct .exposure and inhalation of rado''-222 and pro--, geny do not appear to be significant.' No,.likely meahs of an ingestion

pathway were identified, and inhalation due to fumigative dusting canbe discounted'since' the material is covered and notcsubject to becomingairborne. .An,evaluation of.: the potential for groundwater contaminationcould not beimade in the absence of information concerning the hydro-geologic characteýr of the local area.. 2'•Three. shallpw (about 20 feet)

.. wells in the area were all found to be dry at the time thq IE:IIIinspectors visited the site, precluding collection and analysis of

.groundwater samples. As noted above, 6arium.sulfate and U30 ar0 known-". to be insoluble in water. 3.. .. . .'- 8 k

F

:, ti " ''d

Future Development = . . . . ",

It is noted that the radiuiii 226 concentration of materials".J•

presumed buried at 'the Westý Lake Landfill approximates that foundin tailings materials used for leveling,* aggregate and backfillunder or around the foundations of dwellings in certain westernColorado communities. Some of these Colorado" dwellings experienceindoor radon 222- c6ncentracions capable of yielding s exposuresn' . 5 t'01 Vik, .1 11' . t •U,,. t,;ý'approaching those implied in the occupationa; imits of 10 CFR 20..Differences in fife physical and chemical n1%ures of the West LakeLandfill and the weg.tern Colorado tailings,:i eyr, suggest a ..... .. -lower radon release fraction for materials of the type buriedat the land fill._ Recognizing the potentia, for radon buildup in

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* C'2fl

* ~rnK;~," -

~

I,:,

* .'

T~1

. _ , :. . .. . .. -.. ... ..

. . for ;

,r7.t

3dwellings.and the uncertainties concerning certain parameters neededto estimate that potential at the West Lake Landfill, a completeenvironmental impact assessment is necessary to accurately evaluatethe hazard potential for this pathway.

Comparison with 10 CFR 20 Criteria

Finally, it should be noted that a licensee may bury up to about twotons of natural uranium per year (in twelve. increments) within criteriacontained in 10 CFR 20 concerning depth (4 feet) and spacing (6 footspacing between locations).' Thus, in four years, eight tons could bedisposed of in forty-eight one-sixth ton batches buried in a grid withsix foot centers.,1 Such a g'rd'would comprise an area significantlysmaller than'that .found in this case, while containing about the samequantity of disposed uranium. ' .. *

"!' .01-,' '0: 0 0' 0 . , 0' 0 - .- • .00 0 0 0 0 0

06 6..... ... 0 0 0 6 t0 0 f " . ,

U" . .. 0 0o ' 36 ft "11 m - ...

, 0 0 '00 0 J '.•- " .. Z0 A 0 0 0.0 0.'0 0"0 0 0'0. 0

-• .0 0 0 0 0 0 0.. '.-' . .. .36 ft o 11" .m-. *. - ., -

Conclusion 7. '., .AA: c. • .' r

S Seven ton~s'of uranium could bedisposed of by burial in accordance with10 CFR 20.,304 inan area significantly smaller than that now existingat the West Lake LAndfill. 'sa &ed on our estimates 'of maximum potentialexposure condi&i6fis by varilo,.r-pathways, it is concluded that thematerial now present at the West Lake Landfill does not represent aradiologAcal hazard by any pathway yet ideAtified. Based on studies ofthe use o6f uranium tailings for backfill 'nd leveiing under and aroundresidence foundations in Co]borado, it is estimated that increased indoorradon and radon progeny conc'6.etations could"be ekperienced in strut-tures built directly in or on the dispose tailings. An environmental•.,Ot : 'f1,, .jj '- L , - '., , 't,,'

impact analysis. is required fortan accurate estimate of the-hSazardpotential for this" pathway..'.;- .. i,7A.no

Attachments: --. -..:, n . . , ,1. Attachments A, B, C and •D-.A .,.- . I .2. Exhibits A-E 7••..:., ... T,;.I3. References 1-4 .*, ..

.:•i~f. rr.. "€ ... ,

- 12

ic , • "elu.- . .

. .* * *. •J L . . . • i7 . , . .

I. S

ATTACHHENT A

During a survey performed by this office on August 11, 1976, todetermine the effec'tiveness of Cotter Corporation's decommissioningof their Hazelwood,'Iissouri (Latty Avenue) site, a difference inthe radiation readings supplied by Cotter and those found by thisoffice was noted.

On May 10, 1974, Coiter reported exposure rates which ranged from0.01 to 0.4 mR/hr measured at three feet above grade (type of instru-ment unknown). (Reference 1) These values were the basis fortermination of the license by the Directorate of Licensing.(Reference 2) The Region III August 11, 1976 survey, made at the

. samedistance,' yielded' readings rangin'g fromr-0.3 to 0.8 mrad/hrbeta-gamma. (Referenceii3) Additionally, a survey at one centimeterrevealed two areas rea'ding 1.2 and 1.8 mrad/hr beta-gamma. Theinstrument used by IE:.I1I inspectors in performing these measurementswas an Eberl ne E-500B with an end-wir 4 ow Model HP-190 Hand,,rbe '(1.4-2 mg/cm ). . " :, : .

• - .... , •., •.• •, • • 1 , . .... . . "'The presently acceptable limit for release of ground are:as, as., implied,in the "Decontaminat'io'n Guide" (Referen~c' 4) is 0.4 mrad/hr, tOtal,or 0.2 mrad/hr, average, -with a maximum' of 1.0 mr'ad/hr,- all of -2whiFch are to be meas'ured at 1 cm with a probe of not more than 7 mg/cmof. total adsorber. -,Thius, the NRC Region III survey of August 11, 1976 'showed radiation levels at the Latty Avenue site exceeding the accepta-ble release limits, while the survey performed by Cotter Corporation.showed levels within kthe guidelines. B',rh surveys indicate a low, non-hazardous radiation level. The difference in results might beattributable to diffkrences in instruments and procedures used. The .AAugust 11, 1976 surveys were the first Tihdependehr examination by NRCof radiation levels .at the Latty Avenue 'site."

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ATTACiMENT B

ENVIRONlENTAL SAMPLEAnalytical Results by IISL

Results (uCl/g)

Sample

L-2

L- 3

L-4

ew-2*•Note:

'*-.. 3r ,. - -

No. Sample Description

Soi.-

Natural Uranium

.2Soil

'AVegetatfonlt:ý.

i.- MWet Sediment Fromr-", Cold ;WMa:tefr-:e&reek

• -- f~7 • : '• • t

~' ..~ d.

4--.2 + 0. 1 E-4

'177.5-+ 0. E ,E-5 z. -

" 2. 6, 0 2, E-55> 3.' -+,- 0.4• . E-6':

-. T -- • , . • ' . -

Ra-226

1.4 + 0.03 E-3

5.14 '-0.14 E-4

~i.-1;

4.. .7.-

Soil]

OY- I1 ,I . - -ýC

-ý5 3: +0.-E-6

'I)

-~ e~>.

I) 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, r.epor.ed., as wet) weight .! .,<-4) L-4 dried prior to analysis'5) A: systemic error of + .20% .should be assigned to [Ra'-226-anAlysis ' - "

due to uncertainty of the equilibrium between Rn-222 and Rn-226.An 80% equilibrium ratio was-assumed. . -

-~~~.... .. .".•! --- : .... . .. ...- . ..... ... _.-...

• . ;, ' " ., -i' "',. i :" ! . , •' , - . .. .I • .

01•)L'

.. ',-, .. ",4

V ..

L-3 vege .t.,L-4 dried prior

I- . . . .- :

..-]"T

•rV.1-F-'

- -U-~ .~ . ~

Cl.V¶3

ýr 1.18

~~ sec.

.... A., .

V leate. iýi onS222 EATTACHiENT CRn-222 Emanation Calculations

1. Rn-222 at the Spoils/Cover Interface

Total release 9i (area) (source flux)(1600 mz) x DC° (A/(DS))"

Kraner, et al, the NaturalRadiation Environment, 1964

Assume: -2 2D - 1.5 x 10 cm /sec

3 -Co0 (1.0' nCi/g)(0.6 g/cm )(1 x 10 )- 0.16 nCi/cm3 - 160 pCi/cm3

.. 2.099 x 10 6 sec

S 0.25

1 x 10"- 1 10% "emanation power"(fraction escaping solid soil ga•Tanner, The Natural Radiation-`Environment, 1964

-0.25 soil "void fraction"

Total release.- (,1.6 x 10 7)(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 10-5)7

Total release'.- 2.3 x 105 pCi/sec over 1.6 x 107 cm

area release -" 1.44 x 10-2 pCi/cm 2. sec

Rn-222 at the Surface of the Cover2.

C2 C exp (-Z(A/D)

Assume:C-

I..-

-2 21.44' x 10 !i/cm / sec

-2 '1..5 x o10 cm /se ,-6 1

2.090 x 10 -seI Ob car

.. ,,,Tauner, The Natural RadiationEnvironment,_ 1964

' , : . .

C2 (1.44 x 10-) exp (-100 (2.099 x 1. 1.5.x10

- (1.44 ) exp (-1.18)i l 10-2 ) ''S(1.44 x 102 (0.31Y 0, -

-3 2~C2 4.4 x 10 pCi/cm . sec ., .

Entire area: (4.4 x I03) (1.6 x 107) ? 7-0 x 104 pCi/sec

Therefore, the total emanation rate ij..about 70 nCi/sec, or ab,0.1 jCi/sec., ,~ .. .,.

out

.44

* Zr,>

.11

-~ 3

,i

.3? F-i

3. Atmospheric Dispersion Coefficient

X/Q I/noo• uy z

a and a are calculated using the "virtual point source" methodd~scribeA in Workbook of Atmospheric Dispersion Estimates, asfollows:

- 4.

a. for a square area with 40m sides, a = S/4.3 - 40/4.3 - 9.3m-",. yO..

b. in the area, ao a - 9.3myo

c. at 20m (center of area from side), stability class E, andground-level release, a 1 6'

zd. assume annual avg. windspeed is 2 m/sec"

"( (2' , "m•2: " 3.... .X-IQ-- '1/(3,.14). !)(.9",-)(2)•m'l.?-7 -2 3O..e / :

Concentration in Air ,. i).

2 '3 •3Concentration (0.1 uCi/sec)(l.7 x 10- sec/ ) 1.7 x`10 uCi/

A..

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4SupUPPT.ENTAL PLEVORT

INVESTICAT TO:: rOn L'1RA:TUM-/711:ORI L

00.

COTTER CORUORATTON. LATTY ,V.:UE. sI'r. ST. LOUIS, MISSOUrIa

OCTOJIER 201 1.976

'Pursuant to the ongoing in-:eztigation of pos~ible uranium/thoriumcontamination at the Latty Avenue site, Me.;,.ji., J. A. Pagliaro andG. T. Gibson performed a site inspection on'October 2C, 1976. Thepu-'poze of this iiupection was to identify the property owner.Tfromcounty tax records, ;to survey-the property with L,,ta-gamma andalpha survey instrmtn.bntaticn, and to obtain seC]ectCd soil andvegetation samples for laboratory analyses.

The records reviewed at the St. Louis Coun'ty Building, 41 SouthCentral, St. Louis, Missouri, were the current county property taxrolls. County pfr~cnnel stated the tax records examincd weredated as of July 1976. The record indicated LhCe Lollowing:

Address:' 9200 .a~ct4 Avenue • .: " ' i7 •-".

Owner: . Cotmnercial DiScou'iit Corporntioin55 East Monroe Street

" Chicago, 1lllno1 s 602 r

Size: .. . 3.5 acres "

Telephone communication with I: III was pcrformed to-asce'tainwhether the property had clece been transferred. Additionalinformation wL s receivcd which indicat'ed Comxicrcial I)iscuuntCorporation had Lr;-r..fer red ownership of the property in Augunt 1976to the Bayless Company, 175 Outer Road West," Valley Park, Missouri.

A site investigotion was then performed and samplcs were obtaiued.Figure I indicates the r6l1ative position of various buildings,landmarks, and locations of collected samples. The arca in Fi.gure 1encompassing the abandoncd garage, abandoned warehouse buil.d i4rg,and the abandoned End boarded-up burned building was estima•ed to beapproximately threc (3) acres. The entire aica, including thewarehouse area and plcwed' field, was estimmcd to be in excess ofsix (6) acres.

Sr-

: ythirATTACHMENT D

.. <~~ A -0 'tl

" : "•"'h • :'KDI' . ~ :"'.e a '.icd. dctccta! ] .] ••a • .. ),le. w': l y 1• :; .o a•,npi'

-,-.nr~a~ 41 ai i dn-.cwil

riaL tho'tjur. ando 2 -. • . 23 "' /.hr be

i at cc_ . -a L , ..i.. A." nu ct.' :.. rh -, .. i'a" .' ure a d.. t hei:;:".de• : _

.* -prO';"" .. .

A survey of the plo.%ed field utiliz ing the beta-gamma instrumentsindicated only background activity (<0.1 rnR/hr), except for several

* small yellow-colored chunks of Isurface matei-ial.' The location ofthe "yellow surface" mnat'drial is shown in Figure 1. The "yellowsurface" chunks ranged ih size from 4 x 4 x 1 inches to small flakcs.The material was somewhat fiberous in texture. The "yellow surface"material had an apparent beta-gamma flux of 10 mR/hr at contact.Approximately 1.5 pounds of the "yellow surface" was collected forlaboratory analysis. Several holes were d4g to a depth of 15 inches

but no subsurface yellowmaterial was excavated.

Selected soybean's were €ollected from the plci'ed field, within ten* feet of the "yellow surface" material. Appropi.-ately 1/4 pound

of soybeans were collec ted for -laboratory analysis. A backgroundcontrol soybean sample was obtained later, a distancc of 7 miles

from Latty Avenue. , ,

A rusting abandoned h'opper sho' n in Figure i, was surveyed forbeta-gama and alpha activities. Survey results showed nosignificant activity '.abov:e background (< .1 mR/hr bcta-tamTwa,500--DPf alpha). .. .. , . :

The warehouse building was surveyed with beta-gamina and alphainstrumcnts. The flbor of the warehouse was composed of dirt andbroken concrete. S'ev'eral elevated readings azbova background activitywere recorded. The highest apparent locat.i-fon was in the center ofthe warehouse, beside a support, column. Readings .of up..t"o 0.8 mra1/hrbeta-gamma and 30,000 DP1:4 alpha were observed. A "warehouse dirt"sample, consisting qf approximately 2 pounds of topsoil was obtainedfor laboratory analysis.

. ...... - . ' :.,j. •,, . .

Preliminary radiological analyse's were performed at IE:III usingbeia-garma',' a'Iphia, "and' g'aa-spec troscopy instrumentation. Thesamples were then forwarded to ERDA:Health Scrviccs Laboratory (1SL),Idaho Falls, Idaho.

The results of the iE:.III analyses showed no detectable activityin either soybean sample. The "yellow surface" sample showed10 mR/hr bcta-gafnn.a.,and 4,000 DPf .al2p1a a`icontact with a few gramsof material. Ganuna !Scanning with an unshielded Nal crystal indicatedthe presence of uranium. isotopes,.but not thoriu 4m. and "thorium daughters.The "warehouse dirt" sample showed 0.3 mR/hr bcta-gamma and 26,000 DP:Ialpha at contact with a sample of." :-bout 250 g. Ganuna scanting withNaI indicated both u~raniuxa and thorium and their decay chain productsto be present..

. ~ ~ ~ ~ ~ ý~ • [ " ,:.:C.. ;v, , "

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The results of alpha spectroscopic analyses of the two coil samples by--..HSL are presented in Table I below.-. :J.•SL analyses of the two soybeansamples showed only small quantities4 ,of naturally-occurring K-40.

TABLE I.-

Radionuclide.:-.Alpha SpectroscopicConcentration (uCi/•'.)Sample

Warehouse Dirt

Yellow Material

Th-230 :

Th-226:~. A A

C ~U-238U-234,:~

A) ~U-235 V

.A3 ..61,Ad 6.6,.4

6 6.52

j, 3.09. 5..2.

0.3

0.3

+

.4.

+

-+

0.05.... E-020.-2-. E-04Jo-oQ6•.! E-040.06.,1 E-040. 07:.,. E-05,0.'!;I.-e E-04

0.1 E

0.1 E-02

* AAjAI.

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1* I.AAACA

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Al

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2

col

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