Research on Adverse Health Effects from Rocky Flats on Local Residents: A Summary

Facing plans to build the Jefferson Parkway along the most contaminated edge of the Rocky Flats site and the intent of the U.S. Fish & Wildlife Service to allow public access to much of the still contaminated Rocky Flats site, we need a good summary of studies of health affects from Rocky Flats on people who live or work near the site. The following is my attempt to meet this need.  Of course I welcome comments or questions.

Carl Johnson’s cancer incidence study: In a 1981 study Carl Johnson divided the Denver region into three areas of higher to lower contamination of soil with plutonium released from Rocky Flats and a fourth non-contaminated area. Using data from the National Cancer Institute for 1969-1971, he demonstrated a relation between areas of contamination and cancer incidence in those same areas. The most contaminated area nearest Rocky Flats had 16% more cancer than the non-contaminated area, the intermediate area 10% more cancers, and the contaminated area furthest from Rocky Flats 6% more cancers. (Johnson, “Cancer Incidence in an Area Contaminated with Radionuclides Near a Nuclear Installation,” Ambio, 1981, vol. 10, no. 4, pp. 176-182)

Feasibility study: In 1982 Nancy A. Dreyer and co-workers reported a feasibility study for an epidemiologic study of persons who lived near the plant. They assumed exposure to plutonium began in 1967 and concluded that, based on the environmental data they analyzed, exposures were not high enough to be evaluated with statistical analyses in an epidemiologic study. (Dreyer et al., “The Feasibility of Epidemiologic Studies of Cancer in Residents Near the Rocky Flats Plant,” Health Physics, 1982 vol. 42, no. 1, pp. 65-68)

John Cobb’s autopsy study: In a study that began in 1975 C. U. Medical School professor John C. Cobb and colleagues from EPA measured plutonium concentrations in autopsy samples from more than 500 persons who died in Colorado. They compared those who lived near Rocky Flats with those who lived far from the site and found higher concentrations of plutonium in lung and liver tissue for people who lived near the plant. (Cobb et al., “Plutonium Burdens in People Living Around the Rocky Flats Plant,” March 1983, EPA-600/4-82-069, Springfield, VA: National Technical Information Service)[1]

Crump’s response to Johnson: In 1987 a DOE-funded study by Kenneth S. Crump et al. responded to Carl Johnson’s cancer incidence study. Using the same data and methodology that he used, they replicated his results, but said they found no evidence of “a relation between environmental exposure to plutonium from Rocky Flats and cancer incidence.” They advanced the thesis that cancer rates were highest in inner city Denver due to the “urban effect” rather than proximity to Rocky Flats. To reach this conclusion they abandoned Johnson’s approach and divided the metro area into six equal-sized sectors centered on the State Capitol, then calculated the cancer incidence in each sector. They found that cancer rates in the sector containing Rocky Flats were no higher than other sectors. (Crump et al., “Cancer Incidence Patterns in the Denver Metropolitan Area in Relation to the Rocky Flats Plant,” American Journal of Epidemiology, 1987, vol. 126, no.1, pp. 127-135)[2]

National Cancer Institute study: In 1990, researchers at the National Cancer Institute completed a study of cancer incidence and mortality around 62 nuclear facilities in the U.S. This study compared cancer rates in counties near nuclear facilities, including Rocky Flats, with those for counties farther away. The results show slight elevations for some cancers in some age groups, but these data are hard to interpret because of limited information about other cancer-related factors. For example, Rocky Flats is on the northern edge of Jefferson County, which then had the second highest population of all Colorado counties, only a small portion of which were living where they could be exposed to toxins released from Rocky Flats. (S. Jablon et al., Cancer in Populations Near Nuclear Facilities, NIH Publication No. 90-874. Washington, D.C.: U.S. Government Printing Office, 1990)

Community Needs Assessment: In 1996 nurses at the University of Colorado Health Sciences Center conducted a community needs assessment and concluded that community-based epidemiological studies should occur in areas affected by Rocky Flats. (N. J. Brown et al., Rocky Flats community needs assessment final report, Denver: UCHSC School of Nursing, 1996)

Epidemiologist Richard W. Clapp calls for ongoing medical surveillance: In 1996 Boston University epidemiologist, Richard W. Clapp, found excessive incidence of lung and bone cancers in areas near Rocky Flats and concluded that “the most recent data are indicative of an ongoing health effect and support the need for surveillance of the incidence of cancer and other diseases on a continuing basis in the exposed communities.” (Clapp, Report submitted 13 November 1996 for plaintiff’s counsel in Cook vs. Dow Chemical and Rockwell International, United States District Court, District of Colorado)

Colorado Central Cancer Registry report: In 1998, the Colorado Central Cancer Registry staff at the Colorado Department of Public Health and Environment found that cancer incidence rates for 10 selected regional statistical areas in the general vicinity of the Rocky Flats Plant from 1980-1989 were comparable to those for the rest of the Denver metropolitan area for the same period. (Colorado Central Cancer Registry, Colorado Department of Public Health and Environment, Ratios of Cancer Incidence in Ten Areas Around Rocky Flats, Colorado, compared to the Remainder of Metropolitan Denver, 1980-1989, with Update for Selected Areas, 1990-95)

Historical Public Exposures Studies on Rocky Flats (1990-1999): Otherwise referred to as dose reconstruction studies, the purpose was to identify quantities of contaminants released off-site and the potential health risks posed by these contaminants to nearby communities. The studies attempted to determine if exposures and risks were sufficiently high to be observed in increased cancer rates in the surrounding population. Due to the low levels of exposure, population changes and the fact that no disease can be attributed solely to plutonium, it would be difficult to perform an epidemiologic study. The principal conclusion therefore was that no epidemiological study was warranted. (H. Grogan et al., Technical Summary: Phase II, Rocky Flats Historical Public Exposures Studies, Radiological Assessments Corporation Report No. 14-CDPHE-RF-1999-FINAL, Neeses, South Carolina: Radiological Assessments Corporation, 1999)[3]

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[1] In his interview for the Rocky Flats Oral History project (Maria Rogers Oral History Program, OH1180V), Cobb spoke of plans for his group to expand their autopsy study to determine whether plutonium was present in reproductive organs where via sperm it could adversely affect the health of future generations. The study was halted soon after Reagan took office in 1981 before the reproductive organ research could be completed.

[2] Johnson, in a published response, pointed out that Crump et al. were able to claim less cancer for areas near Rocky Flats only because the sector containing Rocky Flats also included the sizeable unexposed upwind city of Boulder (1970 population 66,870). They thus greatly undercounted cancer incidence related to Rocky Flats. (Johnson, “Cancer incidence patterns in the Denver Metropolitan Area in relation to the Rocky Flats Plant,” American Journal of Epidemiology, 1987, vol. 126, no. 1, p. 153)

[3] An epidemiological study is a statistical analysis of data (such as that done by Carl Johnson and Richard Clapp); it may point to the need for actual medical examination of people from an affected population but it does not involve such. The Historical Public Exposures Studies are sometimes called “health studies,” but no one’s health was studied. There has never been any direct health study or medical monitoring of people who live in areas contaminated with plutonium released from Rocky Flats.

Rocky Flats and the Risk Society

In 1992 German social analyst Ulrich Beck offered a compelling critique of modern industrial society with his book Risk Society. As articulated by Beck, a “risk society” is one in which risks

• are readily produced by human action,
• are officially regarded as minor, and
• are widely accepted by those affected.

This seamless disregard for risk is mirrored in the behavior of the several government agencies that bear official responsibility for conditions at Rocky Flats. Now, whether they support opening the Rocky Flats National Wildlife Refuge to the public or clear the way for construction of the proposed Jefferson Parkway along the eastern, most-contaminated edge of the Rocky Flats site, they repeatedly tell the public:

1. that operations in the past at Rocky Flats contaminated the environment with plutonium and other toxins;
2. that the agencies responsible for public health regard present conditions on and off the site as “safe”; and
3. that the public has therefore no reason for worry.

Beck presents a strong alternative to this disregard for risk. I believe we should carefully consider what he and others in accord with his view have to say. To begin with, the risks to which he refers typically are posed by contaminants that cannot be seen, tasted or smelled. This kind of risk is a relatively new phenomenon; its nuclear form dates only from the 1940s. In the case of Rocky Flats, the principal contaminant is plutonium in the form of minute radioactive particles released into the environment as a result of routine operations and accidents at the now defunct nuclear bomb factory.

The distinctive feature of our modern “risk society” is that the risk is ecological. It damages and destroys the natural ecosystem to which we belong and on which we depend for our very existence, but it does this not immediately but over the long-term.

In The Turning Point (1982) physicist Fritjof Capra of the University of California in Berkeley said that because of the toxicity and 24,000-year half-life of plutonium 239 (used in abundance at Rocky Flats), it should be isolated from the environment for 500,000 years. At Rocky Flats the plutonium was not isolated from the environment but was deposited in it. Because a ceiling was put on how much could be spent on the Superfund “cleanup” of the plutonium-contaminated Rocky Flats site, those responsible for the cleanup finished the job quickly because they made no effort to remove the maximum amount possible of this toxic material. An unknown quantity was purposefully left behind. That plutonium was left behind is bad enough; that the amount left behind has not been quantified makes matters worse.

Plutonium emits alpha radiation. Unlike other forms of radiation, such as gamma rays and x-rays, alpha particles cannot penetrate skin, but when plutonium particles find their way into the body, the damage they create can be much greater than damage caused by x-rays and gamma rays. Plutonium particles lodged within the body steadily bombard surrounding tissue with radiation, very likely for the rest of one’s life. Over time, the result may be cancer, a compromised immune system or some other ailment, including genetic harm that can be transmitted to future generations.

“The black star in the middle of this picture shows the tracks made by alpha rays emitted from a particle of plutonium-239 in the lung tissue of an ape. The alpha rays do not travel very far, but once inside the body, they can penetrate more than 10,000 cells within their range. This set of alpha tracks (magnified 500 times) occurred over a 48-hour period” (Robert Del Tredici, At Work in the Fields of the Bomb [1987], plate 39).

Herman Muller was awarded a Nobel Prize in 1946 for his discovery that radiation damage could affect future generations. He predicted gradual reduction of humankind’s survival ability due to exposure to radiation over multiple generations (“Radiation and Heredity,” American Journal of Public Health, 1964). His work suggests that radiation introduced into the world by humans may in time destroy our species. A British research team concluded that chromosomal damage from plutonium exposure is essentially “infinite,” because the extent of harm to the human gene pool is incalculable (M. A. Khadim et al., Nature, Feb. 1992). Commenting on the work of Khadim’s group, science writer Rob Edwards observed that the resultant “genomic instability” may account for illnesses other than cancer, illnesses so elusive that epidemiology is “powerless” to detect any relationship between their incidence and exposure to radiation (New Scientist, vol. 11, Oct. 1997, pp. 37-40).

Distribution of plutonium contamination from Rocky Flats in becquerels per square meter (one becquerel equals one disintegration or burst of radiation per second). The original version of this map was prepared by P. W. Krey and E. P. Hardy of the Atomic Energy Commission’s Health and Safety Laboratory, New York City, and published in their 1970 report, “Plutonium in Soil Around the Rocky Flats Plant,” HASL 235. Sampling done in September 2011 along Indiana St. by independent scientist Marco Kaltofen showed that present deposits of plutonium are roughly equivalent to the levels measured by Krey and Hardy in 1970. The dotted red line shows the route of the proposed Jefferson Parkway.

What is clear is that the official incautious attitude toward the plutonium remaining in the environment at Rocky Flats after completion of what DOE has called its “risk-based cleanup” means we are gambling with people’s lives now and into the deep future. The government agencies that approved hazardous conditions at Rocky Flats and removed most of the site from the national Superfund list are prime exemplars of the risk society. When they tell us that the contaminants left in the environment are “safe,” what they mean is that they meet official standards for permissible exposure. They rarely emphasize that exposure standards by their very nature allow some level of risk. Besides, their ways of calculating risk do not take into account the enormous range of individual susceptibility to exposure to radiation. What doesn’t harm one may very well harm another.

Of course, those who establish and enforce standards for permissible exposure know as well as I do that the National Academy of Sciences, in its series of studies on Biological Effects of Ionizing Radiation, has repeatedly concluded, most recently in 2006 (BEIR VII), that any exposure to radiation is potentially harmful. This means there is no such thing as a safe dose of radiation, something that Karl Z. Morgan, “the father of health physics” at Oak Ridge, Tennessee, concluded during his studies that began with the Manhattan Project. And those who set and enforce standards for Rocky Flats must certainly be familiar with the British “Committee Examining Radiation Risks of Internal Emitters” which concluded in 2004 that the cancer risk from very low-doses of plutonium may be ten or more times more dangerous than allowed for by existing exposure standards (see http://www.cerrie.org).

This last point is strongly reinforced from a different angle by research done by Tom K. Hei and colleagues of the Center for Radiological Research at Columbia University. They demonstrated that a single plutonium alpha particle induces mutations in mammalian cells. Cells receiving very low doses were more likely to be damaged than destroyed. Replication of these damaged cells constitutes genetic harm, and more such harm per unit dose occurs at very low doses than would occur with higher dose exposures. “These data,” they concluded, “provide direct evidence that a single alpha particle traversing a nucleus will have a high probability of resulting in a mutation and highlight the need for radiation protection at low doses” (Proceedings of the National Academy of Sciences, vol. 94, Apr. 1997). In a follow-up study, they found that “a single alpha particle can induce mutations and chromosome aberrations in [adjacent] cells that received no direct radiation exposure to their DNA,” what is often referred to as “the bystander effect” (Ibid, vol. 98, 4 Dec. 2001).

During more than a decade that I served on oversight and advisory bodies focused on Rocky Flats, when I asked government personnel responsible for public health at Rocky Flats about such studies, I typically got a blank stare, as if I’d trespassed into sacred space for which they held sole responsibility.

For several years I was privileged to be a member of two committees of the National Council on Radiation Protection and Measurements (NCRP), a non-government body that researches radiation health effects and makes recommendations to government and industry regarding exposure standards. I hoped, as a token outsider, that I could persuade this elite body of radiation health specialists to open their deliberations to people directly affected by the exposure standards they were calculating, such as workers in the nuclear industry and people who live or work near nuclear installations. Two activist colleagues and I were invited to make a presentation at the NCRP annual meeting in 2003; there was a vigorous dismissal of what we proposed. Our paper was later published, under the title “Stakeholder Perspectives on Radiation Protection” (Lisa Ledwidge, LeRoy Moore and Lisa Crawford in Health Physics, Sept. 2004). It garnered zero feedback. I soon thereafter resigned from the committees to which I had belonged.

The author at Indiana St. and 96^th Ave. (SE corner of the Rocky Flats National Wildlife Refuge) on a windy day, June 17, 2011. The proposed Jefferson Parkway would pass directly through the spot where he stands. Nearby is earth moved for the Candelas development slated to run across the southern edge of the Rocky Flats site. Photo by Robert Del Tredici.

Regarding those responsible for radiation exposure standards, Beck observes: “Whoever limits pollution has also concurred in it.” Official exposure standards “may indeed prevent the very worst from happening, but they are at the same time ‘blank checks’ to poison nature and mankind a bit” (Risk Society, p. 64). In other words, we give the agencies charged with protecting public health permission to poison us. Because susceptibility to toxins varies widely, who can say which one of us will be among the vulnerable that receive a lethal dose?

Without question, those most vulnerable to plutonium are human infants and children. This is so because:

• A human child is more likely than an adult to stir up dust, to eat dirt, to breathe in gasps, or to scrape a knee or elbow — all ways of taking tiny particles of plutonium into the body.
• Since a child’s body is smaller than an adult’s, internalized plutonium has more damaging power because the ratio of plutonium to body mass is significantly greater,
• Plutonium within a child’s body integrates with the child’s growth and tissue development.
• By contrast to adult humans or other beings, a child’s normal life span provides far more time for internalized alpha emitters to harm her or his health.

In the face of an environment at Rocky Flats contaminated with plutonium particles too small to see but not too small to do damage, the vulnerability of children was a major reason 81% of the 1,280 parties commenting in 2004 told U.S. Fish & Wildlife Service not to allow public access to the Rocky Flats National Wildlife Refuge. Only 11% of commenting parties explicitly favored access. U.S. Fish & Wildlife (sometimes called “Fission Wildlife”) ignored this expression of public opinion and approved access (see U.S. Fish & Wildlife Service, Rocky Flats National Wildlife Refuge: Appendix H, Comments and Responses on the Draft Environmental Impact Statement for the Rocky Flats National Wildlife Refuge, Sept. 2004; for analysis, see http://www.rockyflatsnuclearguardianship.org/required-reading/public-rejects-refuge-access/ ).                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   Beck points out that the afflictions posed by high-tech and ecological risks “have a new quality,” in that “they are no longer tied to their place of origin, the industrial plant. By their nature they endanger all forms of life on this planet.” This is especially true of nuclear pollutants, because “they outlast generations” and transcend space as well as time in that the harmful material has been and will continue to be carried by the wind great distances. Borders are no barriers to the free movement of invisible particles. “In the risk society, the unknown and unintended consequences come to be a dominant force in history and society” (Risk Society, p. 22).

The foregoing doesn’t square with the “cleanup” done at Rocky Flats, based as it was on the assumption that plutonium left behind will not migrate. This conclusion, reached by the multi-year Actinide Migration Evaluation done at the site, was derived from computer modeling more than from empirical observation. But there are numerous empirical observations to counter this conclusion. The two most notable are (1) Dr. M. Iggy Litaor’s direct detection with field instruments of significant surface and sub-surface migration of plutonium in the unusually wet spring of 1995, and (2) ecologist Shawn Smallwood’s 1996 study of burrowing animals at Rocky Flats. Smallwood identified 18 species that dig 10 to 16 feet below the surface and constantly take surface material down and bring buried material up, in the process disturbing in any given year as much as 11 to 12% of surface soil and doing so in a completely unpredictable way, making plutonium particles available for redistribution by wind, rain, traffic, animal, human and other forces (for references and more detail, see “Science compromised,” at http://www.rockyflatsnuclearguardianship.org/leroy-moores-blog/papers-by-leroy-moore-phd-2/ ).

Residential development just off Indiana St. near the southeast corner of the Rocky Flats site. Photo by Robert Del Tredici, May 2011.

An unfortunate characteristic of risk society is that most scientists, especially in the nuclear field, have allied themselves with the centers of power in industry and government. The late Karl Z. Morgan, the “father of health physics” referred to earlier, exemplified this situation. He pioneered the field of radiation safety as part of the Manhattan Project and was for nearly thirty years head of health physics at the Oak Ridge National Lab. He was a founder of both the International Commission on Radiation Protection and the U.S. National Council on Radiation Protection and Measurements, the two leading bodies responsible for recommending standards for permissible exposures to ionizing radiation. And he founded the Health Physics Society to protect people. Originally he and others in this new field believed that there was a threshold of radiation exposure below which harm would not occur, but he came to realize that there is no such thing as a safe dose and, crucially, that exposures at very low doses are more harmful per unit dose than exposures at higher doses. Toward the end of his long career he proposed reducing the maximum allowable lifetime plutonium body burden for nuclear workers 200-fold (American Industrial Hygiene Association Journal, August 1975). His proposal was ignored. After his retirement from the Oak Ridge Lab members of the Health Physics Society treated him as persona non grata. His autobiography, The Angry Genie, explains how this organization came to be dominated by those more interested in protecting the industry rather than the exposed. He cites the moment when a president of the Health Physics Society told his colleagues, “Let’s all put our mouth where our money is” (Morgan and Ken M. Peterson, The Angry Genie: One Man’s Walk through the Nuclear Age, 1998, pp. 115-116).

Carl J. Johnson studied cancer incidence for 1969-1971 among Anglos in three areas downwind of Rocky Flats defined by levels of plutonium contamination in millicuries per square kilometer as compared to the uncontaminated control Area IV. Area I on this map showed 16% more cancer then the non-contaminated area, Area II 12% more cancer, and Area III 6% more (Johnson, “Cancer Incidence in an Area Contaminated with Radionuclides Near a Nuclear Installation,” AMBIO, 10, 4, October 1981, p. 177).

Colorado was fortunate to have an outstanding public health servant in the person of Carl J. Johnson, MD, for several years Director of the Jefferson County Health Department. His best-known study, published in 1981 in Ambio, the journal of the Swedish Royal Academy of Sciences, showed a direct correspondence between areas of plutonium contamination across the Denver metro area and cancer incidence within those same areas, as shown on the map above. Though both the DOE and the State Health Department tried unsuccessfully to discredit this report, it remains as a work of integrity. By the time the study was actually published, however, real estate interests had gained the upper hand within the Jefferson County Commissioners and forced Johnson out of his job. (For a detailed analysis of Johnson’s work, see “Democracy and Public Health at Rocky Flats,” at http://www.rockyflatsnuclearguardianship.org/leroy-moores-blog/papers-by-leroy-moore-phd-2/ ).

Finally, Ulrich Beck says, “Risks of modernization sooner or later also strike those who produce or profit from them. They contain a boomerang effect, which breaks up the pattern of class and national society. Ecological disaster and atomic fallout ignore the borders of nations. Even the rich and powerful are not safe from them” (Risk Society, p. 23). As the effects of the risk society proliferate, populations will be increasingly divided between “the affected” and “the not-yet affected.” Beck’s prognosis for the risk society’s future is more pointed than Muller’s prediction of genetic collapse. “The escalating scarcity of health will drive even those still well off today into the ranks of the ‘soup kitchens’ . . . tomorrow, and the day after tomorrow into the pariah community of the invalid and the wounded. . . Freedom from risk can turn overnight into irreversible affliction.” (Risk Society, p. 40)

Beck points to the necessity for fundamental cultural change, what eco-philosopher Joanna Macy and others refer to as “the great turning” from environmental risk-taking to ecological responsibility. Such a change happens as affected people — and we are all affected — awaken to the dangers of our risk society and join with others to do something about it. The Rocky Flats Nuclear Guardianship project of the Rocky Mountain Peace and Justice Center is devoted to this end. The first principle of the Nuclear Guardianship Ethic is: “Each generation shall endeavor to preserve the foundations of life and well-being for those who come after. To produce and abandon substances that damage following generations is morally unacceptable.” We invite others to join us in the work of Guardianship (see http://www.rockyflatsnuclearguardianship.org ).

Petition opposing Jefferson Parkway and public access to the Rocky Flats Wildlife Refuge

Marcella MacDonald of Superior has produced a petition opposing the Jefferson Parkway and public access to the Rocky Flats Wildlife Refuge. Signed copies will go to elected officials in city, county, state and federal governments. Here is the text:

Building a tolled four-lane highway and future hiking and biking trails on Rocky Flats Wildlife Refuge, formerly Rocky Flats Nuclear Weapons Plant, will cause plutonium and other radioactive materials to be released into the air, soil and water endangering the health, safety and well-being of surrounding communities.  We need to set a precedent to every superfund site that any development on former nuclear sites is not acceptable!

Please sign this petition. To do so, go to  https://www.change.org/petitions/stop-the-building-of-a-toll-road-trails-and-bike-paths-on-rocky-flats-wildlife-refuge

Rocky Flats: Shiloh Krupar and Nuclia Waste

Quite by accident I recently came across Shiloh R. Krupar’s “Transnatural ethics: revisiting the nuclear cleanup of Rocky Flats, CO, through the queer ecology of Nuclia Waste,” Cultural Geographies, May 24, 2012.

I found the article dense, provocative and congenial. In an email message, Krupar, a Georgetown University geographer, describes the article as a bit of an awkward “sandwiching of empirical case-study material on the RF cleanup, with more philosophical speculation on environmental ethics.” She critiques the ethic that guided the Rocky Flats cleanup for “eliminating uncertainty” and assuming that nature is “static and separate from the human.” Those who did the cleanup, she notes, assumed erroneously that nuclear waste left behind will stay put. This made it possible for them to view and to invite others to view the resultant Rocky Flats National Wildlife Refuge as pristine rather than contaminated. Contrary to this dreamlike misperception Krupar says we no longer experience “pure nature” and thus must adopt a “transnatural ethic” that “directs attention toward the impurifications already in existence” and grounds responsibility in awareness of a broader human/nature kinship. She cites the antics of Denver drag queen Nuclia Waste as an example of the cognitive transformation required. Her paper is on line at http://cgj.sagepub.com/content/early/2012/05/24/1474474011433756.abstract?patientinform-links=yes&legid=spcgj;1474474011433756v1  An abundance of information about Nuclia Waste can also be found on the web.

Krupar says she grew up  in Richland, WA, right next door to the DOE’s Hanford facility where plutonium was produced for Rocky Flats, then later in Lakewood, CO, with her family working at Rocky Flats. While she was doing graduate work in geography at the University of California, Berkeley, she began to think about her “embeddedness” in these places.

I will write another blog entry about a remarkable project Shiloh Krupar is doing with Sarah Kranouse of Iowa University. Look for the U.S. Department of TLC.

Kristen Iversen’s remarkable new book about Rocky Flats

Kristen Iversen’s Full Body Burden: Growing Up in the Nuclear Shadow of Rocky Flats (NY: Crown Publishers, 2012), entwines tales of growing up in what her family regarded as a suburban paradise with her own gradually dawning awareness of what it means that they lived immediately downwind of the Rocky Flats nuclear bomb plant. Her superbly written narrative includes stories of both workers inside the facility and people in her neighborhood who wonder if their cancers and other ailments are due to contaminants released from the plant. The government, which holds the trump card in secrecy as well as in defining “permissible exposure,” says this is only conjecture. Iversen shows why the questions won’t go away. Among books written to provide a convincing account of existence in the nuclear era from the perspective of affected people, Full Body Burden sets a very high standard for thoroughness of investigation, clarity of explanation and humane understanding.

Rocky Flats: What about those 65 cartons of evidence?

The FBI raided the Rocky Flats nuclear bomb plant on June 6, 1989, to collect evidence of alleged environmental lawbreaking by plant operator Rockwell International. A Special Grand Jury that spent two-and-a-half years reviewing the evidence in the case called operations at the site “an ongoing criminal enterprise” and called for indictment of several DOE and Rockwell officials. On March 26, 1992, the Department of Justice, however, bypassed the grand jury and announced an out-of-court settlement with Rockwell in which the company pleaded guilty to relatively minor offenses, paid a fine and was absolved of any other wrongdoing. The judge in the case ordered the grand jurors not to reveal anything they had learned in their investigation, and he sealed 65 cartons of documents from the case in the Denver federal courthouse.

In March 2004 Wes McKinley, foreman of the grand jury that reviewed the evidence in the case against Rockwell, and attorney Caron Balkany published The Ambushed Grand Jury, in which they assert that the real purpose of the grand jury investigation was not to prosecute the principal crimes committed at Rocky Flats but to cover them up. They accordingly called for public access to the 65 cartons of documents sealed by court order. After all, the Superfund cleanup at Rocky Flats was nearing completion, and the government agencies responsible for the cleanup had not reviewed the documents in these cartons. This triggered several months of  juggling over the 65 cartons.

In May 2004 then-U.S. Attorney John Suthers (now Colorado Attorney General) announced he’d consider making some of the contents of these cartons available to federal and state regulators of the cleanup. He specified that he meant ­ only documents collected during the FBI raid, not later testimony before the grand jury. Then-Rep. Mark Udall, in whose district Rocky Flats was located, had asked Suthers to make this material available to the regulators, that is, EPA and the Colorado Department of Public Health and Environment (CDPHE). All this was duly reported in the media.

Three months later Ann Imse, writing in the Rocky Mountain News, reported that no one from EPA or CDPHE had asked to review the documents. Spokespersons for these agencies said they did not want to go through all those documents.

In the midst of this backing and forthing regarding the sealed documents, on August 18 former Rocky Flats worker Jacque Brever appeared at a news conference with Wes McKinley and Caron Balkany. At this event, she released a closely documented report alleging that some nuclear waste in the environment at Rocky Flats will not be cleaned up because DOE had provided misleading information to the EPA and CDPHE. http://www.utwatch.org/war/jacquebrever_rockyflatscleanup.html On September 2, the DC-based trade paper Inside Energy quoted a letter sent to Brever by a DOE official at Rocky Flats saying that “no new information about the nature and extent of the environmental contamination at the Site is contained in your paper” and that every area mentioned by Brever had been investigated and included in the cleanup plans for the site. The Inside Energy article contains this telling sentence from Attorney Caron Balkany: “DOE does not deny our documentation that it submitted false data” to the regulators. I read the Rocky Flats official’s letter to Brever at the time that it was sent. It consists wholly of empty assertions devoid of documentation or substantiation of any sort. On that same day, September 2, the Boulder Daily Camera carried an AP article covering much of the same ground as the Inside Energy piece, though the Camera quotes Jon Lipsky, who had led the 1989 FBI raid on Rocky Flats, saying that Brever’s “report was correct.”

What now can be said about the 65 cartons of documents from the FBI raid and the grand jury investigation of Rockwell?

• First, we know that the FBI raid and subsequent grand jury investigation focused on possible violation of federal environmental laws at Rocky Flats.
• Second, we do not know if the 65 cartons of documents that remain sealed in the Denver federal courthouse contain data that should have been reviewed by those responsible for the Superfund cleanup at Rocky Flats. We do know that in 2006 EPA and CDPHE certified the cleanup without ever reviewing these documents, though they had been given the opportunity to review at least some of them.
• Third, given the remarks by Brever and Lipsky and others not cited here (especially some former Rocky Flats workers who recorded their complaints in the Rocky Flats Oral History Project; go to http://www.boulderlibrary.org/oralhistory/ and see Rocky Flats under Special Collections), it is not irrational to want public access to those 65 cartons of documents. I specifically say public access, not government access, because the government agencies responsible for the cleanup at Rocky Flats have already let us down.
• Fourth, until the public has unfettered access to the sealed 65 cartons of documents, there can be no conclusion that the cleanup done at Rocky Fats is adequate, much less that the site is safe. An invisible cloud hangs over everything having to do with Rocky Flats.

Should we live near Rocky Flats? A question from out of the blue

On April 15, 2012, I received a query about the wisdom of buying a house near Rocky Flats. I get several messages like this every year from people I do not know. This one turned into the following wide-ranging exchange. I have edited the messages slightly to protect the identity of the senders:

Dear Dr. Moore,

I would appreciate your advice on the risk of Rocky Flats contaminants in the Superior area. My family (which includes 2 very young children) is currently considering to move to Superior however I read an article on the proposed Jefferson Parkway road and having studied environmental epidemiology I am concerned of a substantially increased risk of plutonium (or other related

contaminant) exposure if my family were to reside toward the south-west corner of Superior. As I am originally from elsewhere I have no local knowledge of this area and information on this topic is difficult to attain.

________________________________________________________________________

I get a message similar to this every couple of months. Here is the response I made on April 16 to this one:

In response to your question, I’m attaching an article (“Plutonium is forever,” on line at http://www.rockyflatsnuclearguardianship.org/leroy-moores-blog/1905-2/ ) that refers to the danger of plutonium released from Rocky Flats. More to the point of your question is the map copied below. produced in 1970 by scientists from the Atomic Energy Commission (predecessor to the present Dept. of Energy, the agency that operated the Rocky Flats nuclear bomb plant). The Rocky Flats site is clearly indicated on this map. The source of the plutonium releases is what was the industrial area at the center of the site, and the map shows the pattern of windblown distribution of plutonium. The southwest corner of Superior is in or quite near the area shown to have some contamination, indeed the least contaminated area near where Indiana St. intersects Hwy. 128 a short distance east of where McCaslin intersects Hwy 128.

No remediation has occurred in this area or in fact anywhere in the eastern side of the Rocky Flats property itself. Plutonium’s long half-life (24,110 years) plus the fact that the most dangerous way to be exposed to it is via inhalation of minute particles such as the ones remaining in the environment of the contaminated area means it will pose a hazard essentially forever from a human perspective. Were I in your shoes I’d not consider purchasing a house so close to the known contaminated area.

If you have further questions, let me know.

Best, LeRoy Moore

MAP TO BE POSTED

Krey-Hardy w highway_jpg

Distribution of plutonium contamination from Rocky Flats in becquerels. (one becquerel equals one disintegration or burst of radiation per second).

The original version of this map was prepared by P. W. Krey and E. P. Hardy of the Atomic Energy Commission’s Health and Safety Laboratory, New York City, and published in their 1970 report, “Plutonium in Soil Around the Rocky Flats Plant,” HASL 235. The above adaptation of their map was used to delineate the area of the class of affected property owners seeking compensation for damage to their property in the Cook v. Dow & Rockwell lawsuit heard in Denver federal court and decided against the corporations in February 2006, a verdict reversed by the Appeals Court in September 2010. The case seems likely to go to the Supreme Court. The dotted red line on this map shows the route for the proposed Jefferson Parkway.

_____________________________________________

Later that same day, April 16, I received the following message:

Dear Dr. Moore,

Thank you for your reply! I am very thankful to have come across your information and as a result we have cancelled our house contract in Superior. I am astounded that development has taken place in such close proximity to the site. In your opinion how far away from the site would be safe to reside? Have there been any studies carried out using electrostatic particle collectors or such that may indicate how far away airborne plutonium etc may have traveled? I also understand that the local waterways were contaminated due to inadequate protection measures.
____________________________________________

I responded as follows:

One hates to be a bearer of not happy news, but unfortunately the situation around Rocky Flats is not a happy one.

Air monitoring was done on a routine basis during production years at Rocky Flats, but the adequacy of the equipment used has been sharply criticized by two specialists, one a meteorologist and the other a biologist. If you’re interested in reading a brief summary of their work, go to http://www.rockyflatsnuclearguardianship.org/leroy-moores-blog/papers-by-leroy-moore-phd-2/ and open the article called Plutonium and People Don’t Mix and read the opening paragraphs of section 2. Failure to Create a Reliable Record of Contamination.

Local waterways were indeed contaminated. One stream that drains the industrial area of the site, Walnut Creek, empties into Great Western Reservoir, formerly the source of drinking water for Broomfield. DOE paid for Broomfield to get its drinking water from another source, and this city now uses Great Western water only for irrigation of parkways and parks. The other stream that drains the industrial area, Woman Creek, empties into Standley Lake, water source for several suburban communities. EPA and CDPHE have certified that the water as safe and indeed Standley Lake is a regional park where boating and swimming occur. Because of Rocky Flats, the State of Colorado has the strictest standard anywhere in the country for plutonium content in surface water. The streams are monitored at the points where they exit the site. Because recent samples collected in upstream areas on the DOE-controlled portion of the Rocky Flats site showed levels of plutonium very much higher than the state allows at the points of compliance downstream, there is concern that these high readings may mean that eventually the state standard may be violated at the points of compliance downstream. Just last month I sent a memo about this issue to the DOE site manager; he replied that they have things under control and that there’s no worry, though he admits they cannot identify the precise source of the plutonium found in the high readings.

So, I think there are reasons to be concerned about Rocky Flats, though the regulators, EPA and CDPHE, disagree.

_____________________________________________

This reply came rather quickly on the same day, April 16:

Dear Dr. Moore,

I read your papers with great interest and am convinced that there is a total lack of epidemiological investigations carried out to ensure the ‘safety’ of Rocky Flats. There would be no study that could prove this area to be safe, even if all confounding factors were controlled for! The more information I find on this topic, the more incredulous it is that any form of human/animal interaction is allowed anywhere near it. I truly appreciate your work on keeping this area guarded and am grateful that my family won’t be moving to a radiation hotbed. Thank you for fighting this never ending uphill battle.

Kindest regards

_____________________________________________

Then on April 19 this came:

Hi, my wife and I found your blog over the weekend, and as a result we backed out of a contract to purchase a house in south Superior.  I wanted to thank you personally for the time and effort you are putting into educating the public about Rocky Flats.  As a token of our appreciation I wanted to put in a small donation towards the soil testing you have performed by Indiana Street. . . .

In the test results you published recently (Feb or March of this year I believe)  the cesium that was discovered in the soil was attributed to Fukushima.  But wasn’t there also some strontium and cesium found at Rocky Flats during the FBI raid in ’89?  Did none of that go offsite?  Admittedly I’ve only been doing research for a couple of days, but there seems to be a dearth of data on that particular topic.

Also, do you have any knowledge of waste from Rocky Flats being dumped outside of the facility?  I am aware of the contamination at Lowry Landfill, but was wondering if there were other spots as well.  I am trying to find which areas I can locate my family in the Denver metro area which are uncontaminated.

Again, thank you for your efforts.

____________________________________________

My response, dated Thursday, April 19:

True, the cesium found with the samples collected along Indiana St came from Fukushima.

There was no strontium in these samples, but strontium was found in the offsite environment at the time of the FBI raid. Jon Lipsky, former FBI agent who led the raid, continues to pay attention to this, as an indication that there was one or more criticalities at Rocky Flats, that is, spontaneous chain reaction that released strontium, etc., material otherwise not present at Rocky Flats.

Other than the illegal dumping of plutonium at the Lowry Landfill I’m not aware of other offsite dumping from RF.

As for settling in the Denver area, Rocky Flats of course is only one of the major sources of contamination. Lowry Landfill, the Lockheed-Martin facility in the far southwest corner of the metro area, and the Rocky Mountain Arsenal, where nerve gas was made, are other major polluter sites. I’d at least want to avoid these.

Good wishes, LeRoy Moore

Citizens seek sampling of air for radioactivity in area at Rocky Flats intended for construction of the Jefferson Parkway

On Tuesday, February 21, 2012, local citizens asked elected officials of the cities most affected to request that EPA and the Colorado Department of Public Health and Environment test airborne dust for its radioactive content in the area at Rocky Flats intended for construction of the Jefferson Parkway.

“It’s no secret that the Rocky Flats site is still contaminated with highly toxic radioactive materials like plutonium and americium,” commented LeRoy Moore of the Rocky Mountain Peace and Justice Center. “Some of us concerned that constructing a highway at Rocky Flats would endanger people’s health sent the following letter. “

To:       City Council, Broomfield, CO

City Council, Westminster, CO

Board of Trustees, Town of Superior, CO

City Council, Arvada, CO

City Council, Golden, CO

From:  LeRoy Moore, PhD, Rocky Mountain Peace & Justice Center

Harvey Nichols, PhD, Emeritus Professor of Biology

W. Gale Biggs, PhD, Meteorological investigator

Chuck Newby, Principal Physicist, Colorado Environmental Analytics, LLC

Paula Elofson-Gardine, Environmental Information Network

Hildegard Hix, Citizen of Arvada

Rick Brownrigg, PhD, Software Engineer

Rob Medina, Citizens Involved in the Northwest Quadrant and  Gothebetterway.org

Re:     Request that affected cities ask EPA and CDPHE to test airborne dust for plutonium and americium content in the area at Rocky Flats intended for construction of the Jefferson Parkway

Date:  February 21, 2012

Building the Jefferson Parkway along the contaminated Indiana St. edge of the Rocky Flats National Wildlife Refuge would endanger public health by stirring up clouds of dust laden with plutonium, americium and other radionuclides.

In 1970 Atomic Energy Commission scientists showed that the area now intended for the proposed highway was contaminated with plutonium released from Rocky Flats. Recent citizen sampling shows that plutonium contamination in the soil in this same area at present is roughly equivalent to what it was in 1970. See: http://leroymoore.wordpress.com/2012/02/10/pusamplingjeffpkwyrfnwr/

Highway construction in the area therefore would stir up clouds of breathable particles of plutonium and other alpha-emitting radionuclides. DOE and EPA state that inhalation is by far the worst way to be exposed to such highly toxic material, since particles that lodge in the body continually irradiate surrounding tissue. The result years later could be cancer and immune suppression, leading to other chronic illnesses.

This reality, plus the documented deficiency of historic air sampling at Rocky Flats (see Nichols on Air Sampling and Biggs on Airborne Emissions at http://rmpjc.org/rocky-flats/ ) forced us to consider setting up our own project to sample airborne dust for radionuclide content along Indiana St. adjacent to the Rocky Flats National Wildlife Refuge. This would provide baseline data for airborne dust along the proposed route. But we think private citizens should not have to cover the costs of needed sampling; it is the responsibility of the affected communities to safeguard the health of their populations.

If the Jefferson Parkway were to be built, the most affected people, aside from highway construction workers, would be residents of Arvada, Broomfield, Westminster, Superior and Golden. We therefore propose that elected representatives of these cities request jointly or as separate bodies that EPA and CDPHE sample airborne dust on both high-wind and low-wind days at the Rocky Flats National Wildlife Refuge area intended for the Jefferson Parkway, with the samples to be analyzed for plutonium and other radionuclide content. The proposed EPA/CDPHE sampling must meet the following conditions:

1.    EPA and CDPHE’s sampling protocols and procedures will be transparent and will be monitored and approved by independent specialists designated by the authors of this message. CDPHE sampling will be conducted separately by both its Air Pollution Control Division and its Radiological Division.

2.    The sampling will begin without delay.

3.    EPA and CDPHE will issue bi-weekly reports of their sampling results, providing a baseline for airborne radionuclide-bearing dust in the area.

4.    If highway construction begins along the eastern edge of the Wildlife Refuge, sampling by EPA and CDPHE of dust for gross alpha content must occur in this area around the clock with computerized real-time report of gross alpha measurements to be disclosed immediately to the public. Gross alpha measurements are important because both thorium and uranium, also alpha-emitters, are present in this soil and thus pose additional inhalation danger, though less than plutonium or americium.

5.    All costs of sampling, analysis, reporting and monitoring are to be borne by the Jefferson Parkway Authority or by some party it designates, such as the U.S. Fish & Wildlife Service. In December 2011 USFWS issued a “Finding of No Significant Impact,” giving itself permission to transfer land to the Jefferson Parkway Authority.

Finally, the parties to whom this message is addressed are asked to provide the signatories of this message a definitive yes or no answer to our proposal within 45 days, that is, by April 6, 2012.

Thank you for your attention to this proposal. Comments or questions can be addressed in writing to LeRoy Moore at leroymoore@earthlink.net.

Cc:       Senator Mark Udall

Senator Michael Bennet

Representative Jared Polis

Representative Ed Perlmutter

Governor John Hickenlooper

Steve Guertin, Director, U.S. Fish & Wildlife Service Region 6

Michael D. Dix, U.S. Fish & Wildlife Service

Steve Berendzen, Rocky Flats National Wildlife Refuge

James B. Martin, Administrator, EPA Region 8

Martha E. Rudolph, Environmental Program Director, CDPHE

Jefferson County Board of County Commissioners

Boulder County Board of County Commissioners

Boulder City Council

Jefferson Parkway Public Highway Authority

Rocky Flats Stewardship Council

Supporters of this letter

Tom Hoffman, Friends of the Foothills

Anne Fenerty, MS, Chemistry

Jenna Hirsch, Lakewood resident, chemist, Air Pollution Testing, Inc.

Jane Bunin, PhD, ecologist

Tanya Ishikawa, Federal Heights, Buffalo Trails Multimedia

Dave Chandler, Arvada resident

Ron Forthofer, PhD, retired professor of biostatistics

Cody Spyker, student at Naropa University

Steven C. Moore and Martha Griffin, residents of Boulder

Carole Gallagher, American Ground Zero: The Secret Nuclear War

Dave and Doris Depenning,  Blue Mountain

John Lodenkampe, The Environmental Group of Coal Creek Canyon

Oak Chezar, professor

Joy Boston, artist

Kim Homer, restauranteur.

Cynda Collins Arsenault, resident of Superior

Christopher Hormel, resident of Boulder County

Greg Marsh,  Citizens Against Rocky Flats Contamination

Debra Odom, concerned voter

Stephen Thomas, professor

Daniel James, MA

Roy Young, conservation geologist, Boulder

Andrew Tirman, Nederland resident & student.

Richard D. Andrews, President, Boulder Innovative Technologies, Inc.

To support this letter, go to this link and sign the petition   http://www.petitions24.com/demand_testing_for_plutonium_dust_at_rocky_flats

Plutonium is forever

Plutonium is forever

By LeRoy Moore and Robert Del Tredici

BOULDER DAILY CAMERA

January 29, 2012

http://www.dailycamera.com/guestopinion/ci_19837234

 

Whether to build the Jefferson Parkway or to turn Rocky Flats near Denver into a playground, the determining factor should not be commercial or residential development. The determining factor should be hot particles of plutonium.

 

A hot particle of plutonium is one that can lodge in air sacs of a lung or be moved via blood elsewhere in the organism. Wherever it resides in the body it irradiates surrounding tissue. A single particle of plutonium can damage more than 10,000 cells within its range.

 

Nobel chemist Glenn Seaborg, who discovered plutonium in 1941, called it “fiendishly toxic, even in small amounts.” Physicist Jeremy Bernstein recently declared plutonium “the world’s most dangerous element.”

 

In 2004, well before U.S. Fish and Wildlife received most of the site of the defunct Rocky Flats nuclear bomb factory to manage as a wildlife refuge, it decided to open the future refuge for public recreation. Never mind that 81 percent of parties commenting on the plan rejected public access. In December the agency made a second decision, to allow construction of the Jefferson Parkway along the plutonium-contaminated eastern edge of Rocky Flats.

 

Implementing the highway decision has been delayed, perhaps stopped, by lawsuits brought by the towns of Superior and Golden. It’s a safe bet that if the parkway or playground decisions are implemented, future generations will curse us for it. For people will inevitably arrive at an understanding of plutonium dangers that today is not yet broadly shared.

 

Those promoting the parkway and playground are ill informed about the long-term hazards of plutonium. Federal and state agencies backing these projects base their support on assurances of a nuclear establishment intent on perpetuating itself.

 

The blindness regarding plutonium on the part of otherwise savvy people is reminiscent of attitudes toward germs in the early 19th century. Some few realized that invisible entities called germs existed and could cause deadly diseases, but many scoffed. By the end of the century, however, the reality of germs and their relation to disease had become common knowledge.

 

Plutonium particles in the soil at Rocky Flats will one way or another, sooner or later, come into people’s lungs and lives, since, with a half-life of 24,000 years, it poses a radiation hazard essentially forever. Minute particles much smaller than germs get brought to the surface by burrowing animals, incautious humans, turbulent geology and extreme weather. Such particles can be carried near and far by the wind and inhaled by unsuspecting people, including children, the most vulnerable. Once inside the body, plutonium does its damage.

 

The late Edward Martell, NCAR radiochemist, pointed out as early as 1970 that the radioactivity from plutonium dust particles at Rocky Flats is “millions of times more intense than that from naturally occurring radioactive dust particles (uranium) of the same size. Minute amounts . . . are sufficient to cause cancer.”

 

Martell maintained that standards for permissible exposure to plutonium are at least 200 times too lenient. He called for the appointment of independent researchers to develop far more stringent standards. This has yet to happen. When in 1983 he heard that antinuclear activists planned to encircle Rocky Flats, he warned: No children or women of childbearing age should go near the place.

 

By now much is known about plutonium, though some uncertainty persists. In 2008 the National Academy of Sciences faulted the EPA for how it handles scientific uncertainty. Too often it treats uncertainty as indicating the absence of a problem rather than the presence of a problem needing deeper study. Those who completed the Superfund cleanup of Rocky Flats in 2005 acknowledged leaving behind an unknown quantity of plutonium. Without referring to the enormous uncertainties this entailed, government agencies declared the site safe. And they have opposed efforts to have signs posted warning people that visiting the wildlife refuge may be hazardous. For them, is an informed public more dangerous than plutonium itself?

 

Several countries, especially in Europe, apply the Precautionary Principle to potentially harmful environmental issues. The Precautionary Principle holds that if a proposed action poses a possible risk, the appropriate response is to step back and not take that risk. Caution should prevail over carelessness.

 

The official response to plutonium in the soil at Rocky Flats has so far been one of carelessness rather than caution. But it is not too late to let caution be our guide. We recognized some time ago that we could not afford to ignore germs. Later we saw that we must avoid asbestos particles at all costs. And rather recently we have learned to shun second-hand smoke. It is now high time for us to realize that nobody needs parkways or playgrounds on land contaminated with unknown quantities of hot plutonium particles.

 

 

LeRoy Moore, a consultant with the Rocky Mountain Peace and Justice Center of Boulder, has focused on the now defunct Rocky Flats nuclear weapons plant since 1979. Robert Del Tredici, a resident of Montreal, is the foremost photographer of the nuclear age. They can be contacted by email at <leroymoore@earthlink.net> and <bdeltredici@hotmail.com>.

 

 

LeRoy Moore at the southeast corner of the Rocky Flats site on a windy day, June 17, 2011. The route of the proposed Jefferson Parkway traverses the area where he stands. The Rocky Flats National Wildlife Refuge is immediately behind him. Photo by Robert Del Tredici.

 

 

Marco Kaltofen’s Technical Report on Sept. 2011 Sampling for Plutonium at Rocky Flats

2 Summer St. | Suite 14 | Natick, MA 01760 | tel.  508 651-1661 | URL:
http://www.Labs.pro

Field investigation and
laboratory report for:

LeRoy Moore, Ph.D.
Rocky Mountain Peace & Justice Center
P. O. Box 1156
Boulder, CO
80306

Prepared by:

Marco Kaltofen, MS, PE, (Civil, Mass.)
Boston Chemical Data Corp.
January 23, 2012

2 Summer St. | Suite 14 | Natick, MA 01760 | tel.  508 651-1661 | URL:
http://www.Labs.pro
Summary of Key Findings

This revised report includes additional plutonium data by PACE Analytical.  Six of
nine soil samples tested by a commercial laboratory found plutonium at 30, 36, 37,
126, 270, and 1,579 pCi/Kg.  The soils contained Pu-238 or Pu-239/Pu-240 or
both.  In a 1992 to 1994 study, offsite soil levels were found at 30 pCi/Kg, (Ref. 3,
p. 177).  The Litaor (1999) study as cited in reference 3 found 5.9 to 400 pCi/Kg in
42 soil samples adjacent to the site.

A 2005 USDOE study found that soil background total plutonium concentrations
at a community distant from Hanford, WA averaged between 3 and 4 pCi/Kg, and
that further study found that contaminated Columbia River sediments at the
Hanford Nuclear Reservation had between 1.6 and 10 pCi/Kg of plutonium, (Ref.
3, p. 178).  Two New Mexico studies found 4.3 to 8.0 pCi/Kg of background
plutonium in soils, (Holliman, 1987, 36 samples, cited by Rocky Flats RAC Report
No. 1-RSALOP-2000-Final, and WIPP Report, 2000, 40 samples, url:
http://www.cemrc.org/reports/00rept/pdf/7-soil.pdf).

In addition to the nine soil samples commercially tested for plutonium, a sample
of tree bark from opposite the site on Indiana Street was found to contain 32
pCi/Kg plutonium as Pu-238.  Soil from that same location had 37 pCi/Kg of Pu-
238, which was above the uncertainty level, but below the MDC.  A study of trees
in France, (Garrec, 1995, Applied Radiation and Isotopes, ref. 1), found a
maximum of 0.25 pCi/Kg of plutonium in tree rings.

All of the locations with positive detections of plutonium were to the east of the
Rocky Flats site, and were on the right of way paralleling Indiana Street.

Reference samples taken at greater distances from the site than any of the
remaining study samples showed high levels of thorium and uranium.  In fact, the
highest levels, (6.56 pCi/g Th and 2.13 pCi/g U), were found in the buried near
subsurface soils of an eroding bank at Eldorado Canyon State Park.  The data does
not show that the presence of these isotopes is caused by activities at Rocky Flats.
In fact, the Jamestown district of Boulder County, Colorado has been known since
1945 as a region that contains thorium and uranium bearing rare earth
mineralizations. Total uranium and total thorium were therefore not usable as
indicators of contamination from the Rocky Flats site.

This left plutonium as the sole radioactive element used as an indicator of
contamination from the Rocky Flats site.  However any individual uranium and
thorium bearing particles that are found to be definitively anthropogenic in origin
by SEM/EDS remain candidate indicators of contamination from the Rocky Flats
site.  The study samples with high total counts were found to contain thorium as
the primary radioactive isotope, based on sodium iodide gamma spectrometry.

2 Summer St. | Suite 14 | Natick, MA 01760 | tel.  508 651-1661 | URL:
http://www.Labs.pro
Trace levels of cesium-134 and cesium-137 were found in two offsite soil samples.
Given the two-year half life of cesium-134, it is unlikely that the material related to
this low level detection originated at Rocky Flats.  While other sources, (USEPA
Radnet data, 2011, and U. Calif. Berkeley, Dept. of Nuclear Engineering, 2011),
have detected these isotopes in the US, presumably as a result of the Fukushima
releases, this is beyond the scope of this study.

The SEM/EDS analyses by Microvision Laboratories were completed on January
17, 2012.  This analysis determines the elemental composition and size of
individual microscopic particles.  The particles are identified for analysis by the
presence of high z nuclei that are viewed in real time on the instrument’s video
monitoring system.  These analyses confirmed that monazites containing thorium,
uranium, and rare earths were present in the samples.  Silicates containing
uranium and thorium were also detected.  Many, but not all, of these particles
were in the respirable size fraction of 0.5 to 5.0 microns.

Microvision also detected particles containing plutonium and lead in its analysis
of dust samples collected due East of the Rocky Flats site during 2010.  A subset of
these particles from the 2010 series also contained traces of americium.

The presence of hot particles, (see note below), containing plutonium is consistent
with the gross analytical findings of plutonium in fine sediments particles at the
ground surface around the eastern border of the former Rocky Flats facility.

Note:

Hot particles are particles that contain substantially more
activity than surrounding inert materials.  When these
particles are in the 0.5 to 5.0 micron size range, they can
present a significant inhalation hazard, which is
substantially different from that imposed by purely
external electromagnetic radiation such as X-rays and
gamma rays.

(References: See Kaltofen, 2011, Tracking radiological
plumes from the Fukushima Daiichi accident,  Oct. 31, 2011
presentation at 139th annual meeting of the APHA,
Washington, DC, Kaltofen, 2010, Microanalysis of
Workplace Dusts from the Mixed Waste Tank Farm of the
Hanford Nuclear Reservation, J. Environmental
Engineering Science, and Kaltofen, 2009, Master’s
Research Report, Worcester Polytechnic Institute,
Microanalysis of Heterogeneous Radiation in Particulate
Matter.)
2 Summer St. | Suite 14 | Natick, MA 01760 | tel.  508 651-1661 | URL:
http://www.Labs.pro
Methods

2010 study: In 2010 a total of four samples, two dusts and two soils, were
received for testing via microanalytical suite for radionuclides.  Samples
were prepped, screened by standard gross radiochemical analyses, and
autoradiographed to determine the degree of total activity and the potential
number of radioactively-hot particles.

Samples were tested via scanning electron microscopy with energy
dispersive X-ray analysis, SEM/EDS, for individual microparticles.  This
method detects both stable and radioactive isotopes.  The presence of
definitively radioactive elements including U, Pu, and Th are noted in the
individual results sections.  Antimony and lead were also reported.

Based on the detected heavy element particles in sample RFCO001D, many
of the heavier elements in this dust were fused or melted aerosol spherical
shot particles. Many of the large particles showed signs of having multiple
phases, fused together like cement or heat-fused grains.  The ! to ” um
thickness of lead screening on many of these shot particles will obscure the
photon returns on any transuranic elements (TRUs) if they are present
inside an aggregate.  Epoxy-fixing and polishing would expose any obscured
TRUs, but this procedure was beyond the scope of this project.

2011 follow up study: Based on these results a field investigation was
undertaken from September 13, 2011 to September 15, 2011.  Forty-five
samples were collected, including seven biological specimens and thirty-
eight surface and shallow buried soils.  Three of the soils were from
reference locations presumed to be subject to reduced influence from the
study site at Rocky Flats, yet still close enough to share similar soil parent
material.  One additional sample was collected of sediment from a
watercourse west of Indiana on March 16, 2011.  This sample was collected
prior to recent ground disturbance by construction at this location.

At the close of the investigation, a total of fifty samples, including the four
2010 samples, had been collected to date.  The 2011 samples included soils
and plant materials.  Soil samples were collected from the top 1 inch, or
from 0.5 or 1.0 feet below the ground surface.  Plant materials included
lichens and bark from mature trees.

All 2011 samples were collected with full chain of custody protocols.
Mapping is via Google Earth Pro, 2011 edition.  Samples were air dried prior
to analysis.  Reference samples were collected from three sites, two east and
one west of the Rocky Flats site.

2 Summer St. | Suite 14 | Natick, MA 01760 | tel.  508 651-1661 | URL:
http://www.Labs.pro
Samples were air dried prior to any analyses to reduce self-absorption of any
radiation.  All samples were measured for total surface alpha, beta, and
gamma activity using a Victoreen counter and a pancake probe.  All samples
were scanned using a Ludlum model 702 sodium iodide gamma
spectrometer, with follow-up analyses using either an Ortech 3 inch sodium
iodide gamma spectrometer or a liquid nitrogen cooled germanium lithium
detector.  All gamma detectors used lead/copper multi element shields of
various sizes to reduce background gamma levels.  Gamma emission lines at
46, 73 and 234 keV were used to monitor thorium and uranium
concentrations.

The concentrations of plutonium were presumed to be at levels below those
of the naturally occurring nuclides of thorium and uranium.  Plutonium
analyses were therefore performed commercially at PACE Analytical of
Pennsylvania.

Samples were prepared for SEM/EDS analyses by sieving to pass a standard
ASTM 150 micron brass screen, and mounted using double sided mounting
tape onto aluminum stubs.

Figure 1a: Area map, 2011 Rocky Flats sample study

2 Summer St. | Suite 14 | Natick, MA 01760 | tel.  508 651-1661 | URL:
http://www.Labs.pro

Analytical methods and instruments

Preparation:  Air-dried whole samples, except for SEM/EDS which is
prepared by drying then sieving to pass a 150 um screen prior to mounting
and analysis

Counting:  Two channel Ludlum model 3030 alpha/beta counter

Counting:  Victoreen rate meter with pancake detector.

Gamma Spectrometry: Ludlum 1 inch portable sodium iodide detector with
single wall lead shield

Gamma Spectrometry: Ortech 3 inch sodium iodide gamma detector with
Canberra multiwall shield

Gamma Spectrometry: LN2 cooled germanium lithium gamma detector.

Gamma Spectrometry, commercial:  PACE Analytical, Walter Miltz
Laboratory, Pennsylvania, for uranium, thorium, and plutonium isotopic
analysis.

SEM/EDS:  Scanning electron microscopy / energy dispersive X-ray analysis
at Microvision Laboratories of Chelmsford, Mass., using a LEO/Brucher
system lithium-drifted silicon detector and high-z Robinson detector at 0.60
nAmperes and 0 to 60 keV acceleration voltage.

Calibration:  Single element 5 nCi Am-241 metallic certified standard and
multinuclide Eckert & Ziegler evaporated metallic salt 0.584 nCi standard
source received on September 12, 2011 for Cd-109, Co-57, Ce-139, Hg-203,
Sn-113, Sr-85, Cs-137, Y-88, and Co-60.

2 Summer St. | Suite 14 | Natick, MA 01760 | tel.  508 651-1661 | URL:
http://www.Labs.pro
Figure 1b: Area map, location of reference samples

Results:

The total activity, measured as sodium iodide gamma counts per second,
was measured for the set of three reference samples and randomly selected
site fence line soil and biota samples.  The mean and standard deviation of
these results are below.  Given that the offsite samples collected at a
significant distance from Rocky Flats have higher gamma counts per second
than the fence line samples, it’s clear from the blank-corrected data below
that total activity is not a reliable indicator of contamination from the Rocky
Flats site.

Reference samples: 3.9 gCPS with SD = 3.7

Biological samples:  0.2 gCPS with SD = 0.6

Fence line soils: 2.1 gCPS with SD = 1.6

Both the reference and fence line samples had gamma spectral lines, (73 keV
and 234 keV), consistent with thorium.  (See appendix) Some of the fence
line samples also had a gamma spectral line at 46 keV, consistent with lead-
210, a daughter isotope of nonfissile uranium-238.  (See appendix)
2 Summer St. | Suite 14 | Natick, MA 01760 | tel.  508 651-1661 | URL:
http://www.Labs.pro
Figure 2: Total activity in soil and plant
material samples, 2011 Rocky Flats sample set

Seven samples of biological material, (lichen and bark from mature trees
more than 6 inches ABH), were collected and analyzed along with the soils.
Total activity in the biological samples was relatively low compared to both
the reference soils and the fence line soils.

Gamma spectral peaks associated with uranium and thorium, (see previous
page), were found in the soil samples.  These were absent in the biological
samples.  This is confirmed in the data from PACE Analytical, which found
an average of 4.36 pCi/g of thorium and 1.59 pCi/g of uranium in the soils,
compared to 0.63 pCi/g of thorium and 0.08 pCi/g of uranium in the
biological samples.

A sample of tree bark collected opposite the site on Indiana, (sample
RFCO044B), contained a quantifiable amount of plutonium 238, at a
concentration of 30. pCi/Kg.  (Note units change.)

Notably, plutonium was not detected in the reference sample taken from
Eldorado Canyon State Park.  In fact, plutonium was only detected in
samples that were along a line on the eastern edge of the Rocky Flats site.
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Figure 3a:  Locations of plutonium detections

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Figure 3b:  Locations of plutonium nondetects

Figure 3c: Pu-239 distribution adapted from 1970 Krey-Hardy report

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The plutonium concentrations faithfully follow the contours shown in the
Krey- Hardy report, with positive detections along Indiana Street directly
east of the site, but nondetects west and south of the site.

The following discussion of the plutonium test results is based on (a),
Toxicological Profile For Plutonium, U.S. Department Of Health And
Human Services Public Health Service Agency For Toxic Substances And
Disease Registry, November 2010, (b), Argonne National Laboratory, EVS
Human Health Fact Sheet, Plutonium, August 2005,
http://www.evs.anl.gov/pub/doc/Plutonium.pdf, and (c), LaVelle et al,
(2002), A Comparative Study of 239,240Pu in Soil Near the Former Rocky
Flats Nuclear Weapons Facility, Golden, CO.

The dust inhalation vs. soil ingestion risk factors for plutonium are:

Lifetime Cancer Mortality Risk

Isotope   Inhalation   Ingestion
(pCi-1)  (pCi-1)

Plutonium-236  2.1 X 10-8  6.9 X 10-11
Plutonium-238  3.0 X 10-8  1.3 X 10-10
Plutonium-239  2.9 X 10-8  1.3 X 10-10
Plutonium-240  2.9 X 10-8  1.3 X 10-10
Plutonium-241  2.8 X 10-10  1.9 X 10-12
Plutonium-242  2.8 X 10-8  1.3 X 10-10
Plutonium-244  2.0 X 10-8  1.3 X 10-10

Based on these lifetime cancer mortality risk factors, inhalation of particles
containing Plutonium is a more significant risk than contact with or
ingestion of soils.

Overall the results of this sampling and analysis campaign are consistent with
previous reported findings on the site, including the following excerpts:

Another source of soil contamination at Rocky Flats was the leakage
of stored plutonium-contaminated oil. Plutonium was present as the
dioxide when it was released. The dioxide was then adsorbed to the
soil. Fugitive dust emissions caused plutonium-contaminated soil to
be distributed away from the spill. Most of the plutonium remained
on the surface, although some was released and migrated downward
through the soil column (citing Little and Whicker 1978, P. 166).

Plutonium has been identified in 6 soil and 9 sediment samples
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collected from 1,689 NPL hazardous waste sites, where it was
detected in some environmental media (HazDat 2007).  P. 166

The particle size expected to be released from either of the above
mentioned sources, (nuclear testing, NPPs, fuel reprocessing), ranges
from 0.3 to 1.1 µm p. 166

Soil samples collected at the RFETS during 1992–1994 were reported
to range from 1.1 Bq/kg (30 pCi/kg) offsite to 57 Bq/kg (1,500
pCi/kg) onsite. P.177  (Note by M. Kaltofen, 0.03 pCi/g is not the
background level, it is the average offsite level.)

Average Pu concentrations in the Hanford 100N, 200/600, and
300/400 areas were 0.004, 0.350, and 0.030 pCi/g
respectively.  The average Pu concentration was 0.0033 pCi/g in a
community distant from Hanford, P.178

Pu in pCi/g was 0.0008 to 0.011 for Columbia River sediment,
median Pu in pCi/g was 0.002 to 0.010 p. 178.

Liao 2008 as cited on P. 182 found an average of 0.008 pCi/g
Pu239/240 from global fallout in the top 11 cm.

The median offsite soil plutonium concentration found in 2002 by LaVelle et al
was 0.265 pCi/g.  The mean offsite soil plutonium concentration found in this
2011 sample set was 0.226 pCi/g.   These central values are within 1 standard
deviation of each other, meaning that there is no statistically significant
difference between these data sets.  This result does not necessarily imply a
static plutonium distribution, rather, it is likely that losses from the fence line
area are offset by added inputs of plutonium from the former Rocky Flats site.

Subsurface results

Four subsurface samples taken at 12 inches below ground surface were
collected along with surface soil samples at these same locations.  There was
no significant difference in total activity or in gamma spectrometry results
for thorium and uranium between surface and subsurface samples.  The
original intent was to determine whether total activity or uranium and
thorium concentration were related to depth.  Due to the high natural
background levels of uranium and thorium, analysis of these two nuclides is
not a sufficient method for investigating surface contamination related to
activity at the Rocky Flats site.

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Below: Ratio of surface to subsurface gamma activity showing mean (0.93)
and 95 percent confidence limits, (2 times the standard deviation).  The two
sets are not significantly different.

Americium

Americium isotopes were not detected in the Rocky Flats soils, except for
trace amounts in a handful of particles found by SEM/EDS.  The sodium
iodide and germanium lithium gamma detectors were standardized against
a calibrated Am-241 source using the sensitive 59.54 keV gamma line.
There were no detections of americium among the soils or biological
samples.

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Summation:

All 50 samples from the 2010 and 2011 sampling campaigns were tested for
total activity and by gamma isotopic analysis.  A subset of the samples was
tested commercially for plutonium, radioactively-hot particles, along with
confirmation testing for uranium and thorium.

Plutonium exceeded reported background levels by two orders of magnitude
at locations that match those noted in the Krey Hardy report.  (P. W. Krey
and E. P. Hardy, 1970, “Plutonium in Soil Around the Rocky Flats Plant”)

Naturally-occurring total activity, uranium, and thorium levels are elevated
in this area, and were not used as indicators of contamination.

There was no statistically significant difference between this data set and the
1970 data set.  Plutonium losses appear to be approximately equal in
magnitude to plutonium inputs in the Indiana St. area.

The portion of the study area surrounding Indiana St. was contaminated
with plutonium isotopes and traces of americium.  This zone also contained
uranium and thorium bearing monazite particles.  Although monazites are
naturally occurring, these particles nevertheless represent an inhalation
hazard, as they were in the respirable size range of 0.5 to 5.0 microns.
Particles of silicates containing uranium and thorium were also detected.

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Sample Record

ID  Depth (in.) Description (soil unless noted)

RFCO001D NA  (2010 collection) duct dust
RFCO002D NA  (2010 collection) vac bag dust
RFCO002S 0  (2010 collection) open space soil
RFCO003S 0  (2010 collection) 96th St. & Indiana

RFCO005S -6  Watercourse on Indiana
RFCO006S 0  Rte. 93S hiking trail
RFCO007S 0  McCaskin Hwy & Rte. 128
RFCO008S 0  McCaskin Hwy & Rte. 128
RFCO009S 0  Indiana and C.C. Canyon Rd.
RFCO010S -12  Indiana and C.C. Canyon Rd.
RFCO011S 0  Reference: N. Garrison & 100th St.
RFCO012S 0  Reference: 100th & N. Simms
RFCO013S 0  Rte. 93 N and Rte. 128
RFCO014S 0  Rte. 128 @ creek bed
RFCO015S -12  Rte. 128 @ creek bed
RFCO016S 0  Indiana southward 0.4 miles
RFCO017S 0  Indiana southward 0.8 miles
RFCO018S 0  Indiana southward 1.2 miles
RFCO019S 0  Indiana southward 1.6 miles
RFCO020S -12  Indiana southward 1.6 miles
RFCO021S 0  Indiana southward 2.0 miles
RFCO022S 0  Indiana southward 2.4 miles
RFCO023S 0  Indiana southward 2.4 miles
RFCO024S 0  Indiana southward 2.8 miles
RFCO025S -12  Indiana southward 2.8 miles

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Sample Record (continued)

ID  Depth (in.) Description (soil unless noted)

RFCO026S 0  Indiana southward 3.2 miles
RFCO027S 0  Indiana southward 3.6 miles
RFCO028S -6  Reference: Eldorado Canyon State Park
RFCO029S 0  93N near plant gate
RFCO030S 0  93N near plant gate
RFCO031S 0  93N at RF entrance sign
RFCO032S 0  93N & Rte. 72
RFCO033B NA  Lichen south side Rte. 72
RFCO034S 0  At south side Rte. 72
RFCO035S 0  At RR bridge south on Indiana
RFCO036Z 0  At RR bridge south on Indiana (stone)
RFCO037S 0  At RR bridge south on Indiana
RFCO038S 0  At RR bridge south on Indiana
RFCO039B NA  Lichen Rte. 27, Gate 17
RFCO040S 0  Rte. 27, Gate 17
RFCO041B NA  Bark, Rte. 128 near McCaslin
RFCO042S 0  Rte. 128 near McCaslin
RFCO043S 0  Indiana near culvert
RFCO044B NA  Bark, large tree, Ind. @ culvert
RFCO045B NA  Bark, Indiana near culvert
RFCO046B NA  Bark, Indiana near culvert
RFCO047S 0  Indiana near culvert
RFCO048B NA  Lichen – on tree W. of Indiana
RFCO049S 0  NE gate area soil on Indiana
RFCO050S 0  NE gate area soil on Indiana

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Total activity record

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Appendix:  Example gamma spectra

top – thorium present,
bottom – uranium and thorium present

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Copy of isotopic Pu, Th, and U laboratory report pages (1 of 3)
(See PACE reports for full results)

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Copy of isotopic Pu, Th, and U laboratory report pages (2 of 3)
(See PACE reports for full results)

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Copy of isotopic Pu, Th, and U laboratory report pages (3 of 3)
(See PACE reports for full results)

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References:

1) Applied Radiation and Isotopes
Volume 46, Issue 11, November 1995, Pages 1271-1278
Proceedings of Plutonium in the Environment
doi:10.1016/0969-8043(95)00170-I

Plutonium in tree rings from France and Japan
J.-P. Garrec, T. Suzuki, Y. Mahara, D.C. Santry, S. Miyahara, M. Sugahara, J. Zheng, A.
Kudo

Abstract
Plutonium, along with other radionuclide concentrations, was measured in evergreen tree
rings from two different locations. This was used as an information source for the past two
centuries. Tree rings are a product of annual layers and thus chronological information is
clearly visible. Three trees were harvested in 1988–1990: a French white fir (137 years old)
and a spruce tree (177 years old) from the France-Germany border near Nancy, France and
a sugi (78 years old) from Nagasaki, Japan. The uniform branchless part of the trunks from
the harvested trees were immediately separated into a set of tree ring samples each of which
contained 3–20 years of growth. The separated samples were mechanically powdered, dried
at 105°C to obtain the dry weight, ashed at 350°C to measure 40K, 134Cs and 137Cs and
ashed again at 600°C to determine 239+240Pu. The highest 239+240 Pu concentration of
30.0 mBq/kg of dry wood was obtained from the tree rings from Nagasaki, located at the
centre of the local fallout of the Pu A-bomb detonated in 1945. This concentration peak was,
however, observed in tree rings of 1965–1967. The concentration was only 2.9 mBq/kg for
the tree rings of 1944–1946. The contribution of the local fallout on the surface soils from
the A-bomb was 181 mBq/cm2 at the harvested area of the tree, while the contribution of
global fallout by many weapons testing was 5.9 mBq/cm2 (or 3.3% total fallout in the
region). The reason for the over 20 year time lag of 239+240Pu uptake by the tree rings is
unknown because many factors influence the routes of Pu into the tree rings. Also the
chemical form of Pu in surface soils may have been changed by the surrounding
environment. The highest concentration in the tree rings from France was 9.4 mBq/kg
which is about 31% of Nagasaki 239 + 240Pu concentration. The harvested area did not
have any recorded Pu sources other than global fallout. An interesting result was that that
distribution of 134Cs and 137Cs concentrations in the French white fir was different from
Nagasaki. Data suggested that these new radionuclide inputs were from the Chernobyl
accident. The mobility (or diffusion coefficient) of cesium is 2–8 cm2/yr. in the portion of
heart-wood tree rings (1870–1955). Although tree rings can record chronological inputs of
various trace elements, some elements cannot be used. These exceptions would be elements
that: (1) are mobile within tree rings; (2) have little understood entry routes to the tree
rings (via roots, leaves or barks); and (3) have unknown biogeochemical behaviour in the
surrounding environment. Further investigation is warranted to use tree rings as a tool to
record past environmental history.

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2) Journal of Environmental Radioactivity
Volume 21, Issue 1, 1993, Pages 55-63

Effectiveness of tree rings for recording Pu history at Nagasaki, Japan, A. Kudo,
T. Suzuki, D.C. Santry, Y. Mahara, S. Miyahara, J.P. Garrec

Abstract
A 78-year-old tree was harvested in 1988 at 2.8 km east of the Nagasaki Pu bomb
hypocentre, where the local fallout of the 1945 blast was highest. The surface soil
concentration of 239 + 240Pu was 64.5 mBq g
!
1
and that of 137Cs was 87.4 mBq g
!
1
. The tree
rings were analyzed for their concentrations of 239 + 240Pu, 137Cs and 40K. Interestingly, the
concentration profiles over seven decades showed that the Pu was immobile, while Cs and K
were mobile in the tree rings. In other words, the Pu concentration profile revealed a
history of Pu in the surrounding environment of Nagasaki. However, the combined routes,
via leaves from the atmospheric deposition and roots from surface soils to tree rings, made
the record less clear. Surprisingly, the Pu from the Nagasaki Pu-bomb in the tree rings of
1946–44 played a minor role in the concentration profile compared to that from global
fallout. This meant that the Pu in the local fallout was less bio-available compared to that of
the global fallout.

3) Toxicological Profile for Plutonium, ATSDR,
(http://www.atsdr.cdc.gov/toxprofiles/tp143-c6.pdf, accessed 11/29/11)

“A fire on May 11, 1969, occurred at the plutonium processing facility at Rocky Flats,
which caused concerns about possible contamination of the surrounding areas (Agency
for Toxic Substances and Disease Registry 2005). Studies showed that while trace
amounts of plutonium were present in soil, the distribution was not consistent with the
wind direction at the time of the fire. It was determined that the major source of
plutonium contamination was leakage from drums of machine oil containing plutonium
that were being stored in an outdoor area (Eisenbud and Gesell 1997). Another source of
soil contamination at Rocky Flats was the leakage of plutonium-contaminated oil.
Plutonium was present as the dioxide when it was released. The dioxide was then
adsorbed to the soil. Fugitive dust emissions caused plutonium-contaminated soil to be
distributed away from the spill. Most of the plutonium remained on the surface, although
some was released and migrated downward through the soil column (Little and Whicker
1978). “

January 23, 2012
Marco Kaltofen, PE, (Civil, Mass.)
For Boston Chemical Data Corp.

End of field investigation and laboratory report