Is Long-term Stewardship Unraveling at Rocky Flats?

In Democracy, Environment, Nuclear Guardianship, Plutonium, Public Health, Rocky Flats on March 2, 2012 at 3:03 am

High Levels of Plutonium and Americium in Surface Water at Rocky Flats and Long-Term Stewardship at the Site

LeRoy Moore, PhD,

Rocky Mountain Peace & Justice Center, February 11, 2012


Recent findings of high levels of plutonium and americium in surface water at Rocky Flats suggest that the Department of Energy’s program of Long-Term Stewardship at the site is already unraveling.

DOE Rocky Flats recently reported these numbers for composite surface water samples of Pu-239/240 and Am-241 at monitoring point GS-10 on South Walnut Creek (a point of evaluation, not a point of compliance):

• Composite sample   7/21/11–8/24/11: Pu = 0.938 pCi/L, Am = 2.97 pCi/L

• Composite sample   7/21/11–8/24/11: Pu = 4.07   pCi/L, Am = 4.01 pCi/L

• Composite sample   8/24/11–9/29/11: Pu = 0.020 pCi/L, Am = 0.044 pCi/L

• Composite sample 9/29/11–10/25/11: Pu = 0.658 pCi/L, Am = 0.877 pCi/L

(from http://www.lm.doe.gov/Rocky_Flats/ContactRecords.aspx )

Multiple exceedances of the state standard: All but one of these readings, (8/24/11–9/29/11) show levels of both plutonium and americium that exceed the 0.15 pCi/L standard for Pu/Am in surface water. DOE’s report says that the plutonium numbers are being discounted but not the americium ones. In the samples cited above, the highest numbers appear in the second sample for 7/21/11­8/24/11 when the level for Pu (4.07 pCi/L) is 27.13 times the 0.15 standard, and the level for Am (4.01 pCi/L) is 26.73 times the standard. Whether we look at both Pu and Am, or at Am alone, the quantity is about 27 times the established standard.

Relation to breaching of dams: Last summer DOE issued an environmental assessment and Finding of No Significant Impact, giving itself a green light to breach dams of holding ponds in North Walnut Creek, South Walnut Creek, Woman Creek and the Present Landfill pond. Historically the role of the holding ponds was to prevent contaminants like plutonium from continuing downstream so that when surface water reaches the site boundary it meets the state’s 0.15 pCi/L standard. Given the recent report that plutonium and americium levels in surface water at a point of evaluation exceed the established standard, and given the decision to breach the holding pond dams and to return free-flow to the streams at Rocky Flats, isn’t it reasonable to expect that the surface water standard will be violated downstream where it exits the DOE site?

An overlooked warning: A 2001 report done as part of the Rocky Flats Actinide Migration Evaluation concluded that cleanup of plutonium in soil at Rocky Flats to as low as 10 pCi/g (by contrast to the gradated 50+ actually adopted) would result in failure at areas downstream of the 903 Pad to meet the 0.15 pCi/L standard for Pu/Am in surface water (see Win Chromec, Report on Soil Erosion and Surface Water Sediment Transport Modeling for the Actinide Migration Evaluation at the Rocky Flats Environmental Technology Site, Kaiser-Hill Co., 00-RF-01823/DOE-00-93258, February 2001, pp. E-3, E-4). The author of this report thought it would be impossible to pin down the precise source of the plutonium in surface water that would fail to meet the standard, much less to predict when such failure would occur. The report focused on areas downstream of the 903 Pad, that is, on the Woman Creek watershed. Is it possible that what the report concluded about that watershed could also occur in the Walnut Creek watershed where the recent surprisingly high readings for Pu/Am in surface water were recorded? This report was part of Kaiser-Hill’s AME work, but it was not cited in the final summary of the AME project. While the report warned that elevated levels of plutonium will eventually show up in surface water, the AME’s final summary announced a very contrary conclusion, one that became the foundational assumption for the Rocky Flats “cleanup,” namely, that plutonium left in the Rocky Flats environment will be “relatively immobile” (see Kaiser-Hill, AME Pathway Analysis Summary Report, ER-108, April 2004).

A prediction from the past: A National Academy of Sciences report on long-term stewardship of DOE sites published a dozen years ago concluded that “DOE’s preferred solutions ­ reliance on engineered barriers and institutional controls – are inherently failure prone.” Further, “much of our current knowledge of the long-term behavior of wastes in environmental media may eventually be proven wrong. Planning and implementation at these sites must proceed in ways that are cognizant of this potential fallibility and uncertainty.” (Tom Leschine et al, Long-term Institutional Management of U.S. Department of Energy Legacy Waste Sites, National Academy Press, 2000, pp. 4 and 5). What happened at Rocky Flats was precisely the opposite of what the NAS recommended in that, as noted above, those responsible for the “cleanup” assumed that plutonium left in the environment would be “relatively immobile.” The recently reported high levels of Pu/Am in surface water suggest that this assumption is not simply false but harmfully so.

The NAS authors realized that the very concept of long-term stewardship is foreign to our conventional patterns of thought and action, that we don’t typically take the kind of long-term view necessary for dealing with long-lived radionuclides. What is showing up at Rocky Flats, however, is not something long-term but something very short-term. In 2011, a mere six years after completion of the “cleanup,” we have a very short-term environmental consequence of plutonium migration, and, second, we have a failure of physical or engineered barriers not because those barriers collapsed on their own but because DOE authorities, with the complicity of the regulators, made what appears to be a hasty decision to breach the dams of holding ponds. When the water flows freely, how long before plutonium and americium move with it? How long before we see the surface water standard violated?


  1. Scott Surovchak, DOE Manager of the Rocky Flats Site sent the following email:

    Subject: RE: Pu in Surface Water and LTS
    Date: Mon, 12 Mar 2012 08:17:10 -0600
    Thread-Topic: Pu in Surface Water and LTS
    From: “Surovchak, Scott”
    To: “LeRoy Moore”
    Cc: “Carl Spreng” ,
    “EPA RF”

    Dear Dr. Moore,

    Thank you for your continuing interest in the Rocky Flats Site. In
    response to your questions, I would like to refer you to the Rocky Flats
    Cleanup Agreement (RFCA), the Rocky Flats Corrective Action
    Decision/Record of Decision (CAD/ROD), and the Rocky Flats Legacy
    Management Agreement (RFLMA), which are regulatory documents that
    respectively guided the cleanup and selected and implemented the final
    remedy for the Rocky Flats Site.

    The Surface Water Remedial Action Objective (RAO), as stated in Section
    12, RAOs, of the CAD/ROD, is to meet surface water quality standards,
    which are set by the Colorado Water Quality Control Commission.

    At time the CAD/ROD was approved, this RAO was met at all RFCA surface
    water Points of Compliance (POCs) and continues to do so. However, as
    noted in the CAD/ROD evaluation of this RAO, surface water in the
    Central OU does not always meet Colorado surface water quality standards
    at some monitoring points upstream of the Rocky Flats POCs.

    Points of Evaluation (POEs) are established in CAD/ROD Section 17 in
    order to monitor the quality of water flowing from the former Rocky
    Flats Industrial Area. At a minimum, POEs are monitored for those
    parameters monitored at the POCs; additional, drainage-specific
    constituents may also be monitored.

    Under RFLMA, POEs (and additional performance monitoring locations)
    serve to monitor the quality of surface water in the Central OU. POCs
    are used to demonstrate compliance with the surface-water standards in
    RFLMA Table 1 and POE results are evaluated in accordance with RFLMA
    Figure 6. (RFLMA Att 2, sec. 5.1)

    A RFLMA reportable condition occurs when water quality at a POE or POC
    exceeds specific threshold criteria defined in the RFLMA for the
    corresponding monitoring location. A reportable condition at a POE
    triggers notification and consultation with the RFLMA Parties, the
    Colorado Department of Public Health and Environment and the U.S.
    Environmental Protection Agency. The objective of the consultation is to
    determine a course of action to address the reportable condition and to
    ensure the remedy remains protective. (RFLMA Section 6.0)

    As you are aware, the RFLMA Parties have consulted regarding the
    reportable condition at GS10 and an evaluation is being conducted to
    determine a course of action (see RFLMA Contact Record 2011-08). Based
    on our evaluation monitoring to date, we do not believe there is a
    likelihood the standard would be exceeded at the POCs.

    The potential for migration of residual contamination in the surface
    water leaving Rocky Flats is precisely why we monitor at the POEs and,
    particularly, at the POCs. In the GS10 evaluation we are considering the
    items you have kindly reiterated. This evaluation is not complete, as
    it depends upon there being water present at the various locations
    targeted for sampling.

    As you are probably aware, GS10 Pu and Am levels were often above
    standards for many years prior to completion of cleanup and closure. It
    is important to note that as a result of cleanup and closure,
    post-closure Pu and Am annual volume-weighted average concentrations
    measured at GS10 are approximately 30 percent lower than their
    pre-closure volume-weighted average concentrations. In addition, the
    post-closure land configuration results in lower annual average surface
    water volumes at GS10, so the annual average mass of Pu and Am measured
    at GS10 is an order of magnitude lower than during pre-closure

    We believe the post-closure monitoring results do show that residual
    Pu/Am is “relatively immobile,” a geochemical characteristic of these
    actinides that was demonstrated during the years of pre-closure study
    performed by the respected independent scientists forming the Actinide
    Migration panel. Furthermore, monitoring results downstream of GS10
    continue to remain well below RFLMA standards.

    The AME report did not restrict its observations and conclusions to the
    Woman Creek (i.e., SW027) drainage, but addressed several other
    drainages, including GS10. The report noted that Pu/Am movement
    mechanisms in the GS10 drainage were similar to SW027, and that soil
    transport was likely the vastly predominant mechanism, but did not rule
    out other possible mechanisms, such as colloidal transport. Therefore,
    our ongoing evaluation is not restricted to the erosional transport

    The GS10 evaluation depends on results of monitoring, and we are
    continuing to gather monitoring data. Those data will help further
    refine and focus monitoring to identify the location and geochemistry of
    residual contamination, and potential responses to these conditions.

    We will continue to report and inform the public of the findings of the
    evaluation and the course of action, and trust that you will continue to
    be vigilant in reviewing our findings and any course of action that may
    be proposed.

    Scott Surovchak
    U.S. Department of Energy Office of Legacy Management
    Rocky Flats Site Manager

    • This is a polite message that essentially says they (DOE, EPA and CDPHE) are looking into the situation of the high concentrations of Pu/Am I had addressed. No mention is made of the dam breachings. And interestingly, despite samples showing Pu and Am at levels that exceeded the surface water standards by 27 times Surovchak says the assumption that Pu remaining in the environment is “relatively immobile” still holds. He also makes no reference to the document I cited that said Pu/Am should be expected at some point in time to exceed the state’s surface water standard even if the site was cleaned to 10 pCi/g, which of course it was not. He likewise says nothing about the unraveling of long term stewardship at Rocky Flats.

      A friend who like myself has followed these issues closely for years wrote this: “Well this reply is one fantastic job of word smithing…paragraph after paragraph of nothing. Actually I think this letter is demeaning to you..It is a reply to someone who has never been exposed to RFETS and the cleanup. I think these exceedences are sure important. I cannot understand their logic that the Pu and Am will stay on site unless the flow will be so slow that it.may not be enough to catch in the samplers at the POE’s. Their averaging also hides their sins.”

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