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EPA and West Lake Landfill or how the EPA ended up with responsiblity In 1967, Continental's lender took possession of the residues, which wereeventually sold to Cotter Corporation. Most residues were shipped to Cotter'sCanon City uranium mill; with the barium sulfate cake as an apparent remnant.Without nuclear licensing approval, the barium sulfate cake was mixed withsoil and hauled to the West Lake Landfill for disposal. License documentsindicate that: (1) this disposal was a license violation and (2) it would nothave been authorized if licensing approval had been sought.Cotter's ultimate disposal of the barium sulfate cake at the West LakeLandfill does not alter our determination that the material had commercialvalue when originally sold by the AEC. Continental Mining and Milling, theoriginal purchaser, had designed specific processes for extraction of uraniumfrom the barium sulfate cake,, and the licensing record shows the involvementof Continental and its predecessor with this process for a period of years.In fact, the record also shows that Continental Mining and Milling intended toprocess the material at its Latty Avenue site and was willing to pay thecapital costs and take the business risk of establishing a new. facility forthat purpose.From the time of the original AEC sale, all materials were considered to be"source material,""and all owners were licensed under the Atomic Energy Act.Owners, had an obligation to meet the licensing requirements and to factor thecost of those requirements into their business decisions. In 1976, the NRCRegional Director articulated the same position:"The Cotter Corporation, which was responsible for this burial,was an AEC licensee -- not an AEC subcontractor. Consequently,the Energy Research and Development Administration [a DOEpredecessor] has no responsibility with regard to this material.As a former licensee, the NRC will look to Cotter Corporation tocorrect any safety or environmental related problems identifiedthrough our investigation." West lake Landfill monitoring sites 452 Radiologically impacted material sites https://epa.maps.arcgis.com/apps/dashboards/226954d715f041a0bfae9e4a01e878af