PROCEEDINGS OF PUBLIC HEARINGS
PLUTONIUM AND THE OTHER
TRANSURANIUM ELEMENTS
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VOLUME 2
PROCEEDINGS OF HEARINGS
IN DENVER, COLOR ADO
JANUARY 10, 1975
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U.S. ENVIRON MENTAL PROTECTION AGENCY
Office of Radiation Programs
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PROCEEDINGS OF PUBLIC HEARINGS:
PLUTONIUM AND THE OTHER
TRANSURANIUM ELEMENTS
VOLUME 2
PROCEEDINGS OF HEARINGS IN
DENVER, COLORAI
JANUARY 10, If
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Chicago, Hi:nc.l3 C0:0«*
U.S. ENVIRONMENTAL PROTECTION AGENCY
Officr of Radiation Programs
Criteria and Standards Division
Washington, D.C. 20460
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FOREWORD
Production and use of plutonium and the other transuranium elements
is projected to increase rapidly. Because of the long half-lives and
high radiotoxicity of many nuclides of these elements, public and tech-
nical concern has been expressed regarding the possible environmental
and health impact of releases of these elements to the environment. For
this reason the Environmental Protection Agency has embarked on a pro-
gram to evaluate the environmental impact of the transuranium elements
and to consider whether further guidelines or standards are needed to
assure adequate protection of the general ambient environment and of the
public health from potential contamination of the environment by radio-
nuclides of these elements.
As a part of this program public hearings were held in Washington,
D.C., and Denver, Colorado, to gather information regarding the public
and social implications of plutonium utilization; the factors involved
in the balancing of costs vs. benefits; dosimetry, health, and environ-
mental effects; environmental levels and pathways; applications using
plutonium; and control and cleanup technology.
This Agency believes that the information resulting from these
hearings constitutes a significant contribution to the public awareness
and knowledge of this problem and that wide dissemination of these
proceedings will be valuable.
W. D. Rowe, Ph.D.
Deputy Assistant Administrator
for Radiation Programs
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PREFACE
Information was presented both orally and in written form
at the hearings and, in addition, a number of letters were sub-
mitted directly to the Office of Radiation Programs of The U. S.
Environmental Protection Agency for inclusion in the hearing
record. This information is being published in three volumes:
Volume 1 contains the proceedings of the hearing in Washington, D.C.;
Volume 2 the proceedings of the hearing in Denver, Colorado; and
Volume 3 the additional material submitted. Where written submittals
are more complete, these are printed in lieu of the oral testimony.
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CONTENTS
Page
Opening Remarks
Mr. John A. Green 1
Dr. William D. Rowe 5
Dr. William A. Mills 12
U. S. Atomic Energy Commission
(Energy Research and Development Administration)
Dr. William W. Burr, Jr 17
Mr. Earl W. Bean 25
The Colorado Department of Health
Mr. Albert J. Hazle 183
City of Boulder, Colorado
Ms. Ruth Correll 203
Jefferson County Health Department
Dr. Carl J. Johnson 208
Colorado Medical Society
Dr. John C. Seiner 224
Lamm-Wirth Rocky Flats Task Force
Dr. John C. Cobb 235
Colorado American Friends Service Committee
Miss Susan Carpenter 267
Dr. Eric Eisenbud, Hospital Physician 282
Prof. Donald P. Geesaman, University of Minnesota 291
Dr. Edward A. Martell, National Center for
Atmospheric Research 407
Mr. George Pelton, Natural Hygienist 458
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Page
Dr. Frank W. Anders, University of Northern Colorado 465
Environmental Action of Colorado
Mr. Albert Nunez 479
Mr. Morey Wolf son 484
People for Rational Energy Sources
Mr. Carl Lehrburger 517
St. Mary's Episcopal Church
Ms. Nina Conant 523
South High School, Denver
Mr. Mike Tryen 532
Mr. Rick Speed 543
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9 :07 a.m.
CHAIRMAN MILLS: This is a public hearing on
Plutonium and the transuranium element. This particular
hearing was announced in.the Federal Register on December 24,
1974, to be held here in Denver.
For some opening remarks, I would like to call on
Mr. John Green, who is the Regional Administrator in Region
VIII located here in Denver for some comments from the
Environmental Protection Agency. Mr. Green?
MR. GREEN: First of all I would like to welcome
everyone to Denver, anyone who is not from the vicinity here.
Welcome to the panel, welcome to our EPA headquarters people,
and I want to thank them for the opportunity of allowing
people in our Region to have some input into these hearings.
I
As you realize, the original hearings were in Mashing ton. Thi
is more or less an extension of those. We do have significant
problems in this area out here, and I do want to express my
appreciation to the EPA headquarters people, to 3ill Rowe,
especially, who heads it in allowing us to have it here.
THE AUDIENCE: We can't hear.
MR. GREEN: What I just did is welcome everybody.
Now, as we all know, as Dr. Hills said, this is an
information-gathering hearing to better enable us to assess
the requirements for standards, regulations, and this type of
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thing. EPA intends to evaluate the environmental impact of
the transuranium elements and to determine whether guidelines
or standards are allowed under our authority to promulgate are
really needed. I am hopeful that these determinations will
assure that there is adequate protection of the general
environment and the public health, especially, that is from
the potential contamination of the radioactive elements that
we are addressing today.
During the course of the day, we will be interested
in any information and all information pertinent to the
development of such standards and, with that in mind, the rules,
that the Chairman will address later are a very flexible and
very informal type of meeting.
Now, for some specifics of the problem before us.
The elements which we are considering here are plutoniurn,
neptunium, americium, curium, and all the others up through
Atomic' Number 103. These elements, as we all know, are man-
made elements. Forty years ago they were unknown for man.
Today, however, they are produced in large quantities, and they
form a central part of our national defense, nuclear power '
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industry, and our space research program. These elements are
also beginning to appear in consumer items such as smoke
detectors, as we use in our air pollution business, and static
eliminators. Research and development is also underway on
such items as heart pacemakers and heart pumps. So, as we yo
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on and on, this list is expanding as larger quantities of
these materials become available.
While the environmental contamination levels are
certainly a topic of great interest to us here, I think it is
worthwhile at this time to put this problem in a perspective.
There is already a large existent worldwide inventory of
Plutonium, fairly uniformly distributed, that is on the order
of 300,000 to 500,000 curies throughout the universe. This is
the result of fallout from various atmospheric weapons tests
and from the burnup of a space nuclear power generator on its
reentry to the earth's atmosphere here on the earth.
Local contamination levels also are something that
we are concerned with, like for example in the vicinity of
Rocky Flats, but we feel these contaminations and locations
of atomic test sites in areas such as Rocky Flats are
relatively small when you look at the total overall levels
throughout the world. For example, the total release from the
Rocky Flats facility over the entire period of operation is
reported to be about 15 curies, with about one-third of this
being off-site. This is not to minimize the importance of
environmental contamination, but rather to emphasize that this
is both a global and local problem.
Now, we feel at this time there is a good reason for
EPA to consider the subject of standards of elements now,
especially at this time. Earlier decisions concerned with
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Plutonium were predicted solely on the basis of national
security considerations inasmuch as plutonium produced was
destined for weapons programs. The Rocky Flats plant and the
Nevada test site are examples of this phase of our development.
Only a recent growth of the nuclear power industry has brought
this problem into the national area.
Plutonium and other transuranium elements are
produced in substantial quantities during the operation of
light water reactors, for example. The materials are contained
in fuel rods and cannot escape except in extremely unlikely
event of a catastrophic event. However, there is a finite
possibility for a small release, and this does exist 1n certain
operations such as fuel reprocessing, fabrication, and
transportation operations. Such releases are expected to
occur under normal conditions, but will require careful control
and surveillance. The nuclear power industry is now embarking
on a growth period, and the problems of today may be very, very
more significant tomorrow.
One significant item is the persistence of these
elements in the human time scale. Plutonium-239, for example,
has a radioactive half-life of over 24-thousand years. Therefore,
remedial measures are difficult to apply to these elements,
and only preventive action is completely satisfactory. The
time to think about this preventive action is right now, and
that 1s our purpose for being here today to study this, to look
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at it, and to get Inputs, and to determine whether preventive
action is necessary; whether it is in the form of a joint
regulation, whether it is in the form of various types of
standards, and whatever can be developed to assure that we do
prevent any future increase, significant increase in the level
of these radioactive lives in the environment.
Thank you.
CHAIRMAN MILLS: Thank you very much, Mr. Green. Novji
I would like to call on Dr. William Rowe, who is the Deputy
Assistant Administrator for Radiation Programs in the
Environmental Protection Agency.
DR. ROWE: We are pleased to be in Denver to continu
our public hearings on plutonium and the other transuranium
elements. As John Green has said, the purpose of these
hearings is to give both the scientific community and the
general public a forum for discussion of all the issues
pertinent to the development of standards designed to limit
the environmental dispersion of these elements to levels both
realistic and safe. We are soliciting such information now,
prior to the time when the Environmental Protection Agency is
ready to write such standards, in order to give the maximum
opportunity for all participants to have their opportunity to
talk early in the standards development process.
The Environmental Protection Agency is keenly aware
of the potential for both use and misuse of plutonium and the
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other transuranium elements. Some of the major decisions
leading to our current environmental contamination levels,
such as decisions on atmospheric testing of nuclear devices,
were mad'e long ago and must be considered as past history.
However, because of the very long persistence of these elements
in the environment, the consequences of such decisions continue*
on and must be part of any realistic assessment of current
and future activities. What we can do now is to make the best
assessment of the consequences of current and future activities
and develop such standards as may be required to best protect
our population. The development of such standards requires
a broad range of detailed information and of informed viewpoints.
Our purpose here today is to help us gather as much of such
information as possible from the total spectrum of opinion in
order for us to do the best possible job.
The establishment of regulatory standards and
radiation guidance involves three different types of judgment
which must be clearly recognized. It is information which will
permit us to make such judgments that we desire here today.
First, we have the technical judgment. Groups of
related facts may on occasion be given different interpretation
by the experts, and result in different conclusions. The
rationale and validity of these conclusions then needs to be
examined from the viewpoint of their influence on standard
setting. In addition, there are always areas where the results
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may not be definitive and uncertainties remain. While it may
be possible to conduct scientific experiments to reduce such
uncertainties, the time to carry out these experiments may
preclude the necessary information being available at the time
action is needed. Therefore, experts in the technical problem
area often must make collective value judgments on the inter-
pretation of available information. I want to say that the
technical expert panels that we use in EPA are usually not
part of EPA, but are various scientific groups such as the
National Academy of Science, National Committee of Radiation
Protection, and other scientific groups who advise EPA on
these technical matters and judgments. In this vein, we seek
information which will help EPA and external technical bodies
upon whom EPA relies to make these technical judgments.
The second type of judgment is the one where the
best technical information as to risks, costs and benefits is
considered and balanced to achieve equitable standards for
society as a whole. In making a regulatory balance of this
type, not only must costs and benefits be balanced as a whole,
but inequities where cost and risk impact on those who do not
directly receive benefits must be considered in terms of the
total and ultimate impact of this activity. In the case of
plutonium and the actinides this involves consideration of
potential health effects committed for long periods. This
type of value judgment must be made by society as a whole and
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not by the technical community alone. We seek information
today which help us to make these risk-cost-benefit judgments.
The third type of value judgment is in that arena
that when standards are set they must be capable of being
implemented and enforced in a way that is visible, traceable
and reportable, and can be substantiated in an evidentiary
manner in the courts. These judgments of a managerial nature
as to the best means of implementing a standard certainly
affect the form of a standard. We here also seek information
which will help us to make judgments on implementation.
It is not by chance that the Environmental Protection
Agency's Office of Radiation Programs has selected plutonium
and the other transuranic elements as the first problem to be
considered in this type of forum. The toxicity and long life
of plutonium and the transuranium elements, totally man-made
elements, provide us with the need for making value judgments
which will now have long-term significance.
The objective of these hearings is to provide a
forum where all existing information on plutonium and transu-
ranic elements which affects radiation protection activities
can be aired and can be considered in a meaningful way, where
all points of view and all who wish to provide input can have
an opportunity to be heard in a studied manner. It is our
opinion at EPA that this information can be best derived by
the type of hearing format we are using here -- where the
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procedures are informal and a panel of technical experts is
used to assure that the information presented is sufficiently
clear for public recognition of all viewpoints. The information
that we seek at these hearings is to provide a baseline of
technical information on radiation protection aspects of the
transuranics, but also can be addressed to any one or all of
the value judgments that I have described.
At the close of the hearings today, the record will
remain open for 30 days, and any further information can be
presented to EPA, Office of Radiation Programs, 30 days from
today, will be included in the record.
This will not be the only source of information that
we use as we set standards. We will be talking with other
bodies as well, but this will become a very important portion
of our standards setting information base. The standards we
seek to set for plutonium are all inclusive.
In many cases the particular authorities and
jurisdictions that set these standards is not totally within
the EPA, and in some cases not even clear where the
responsibility lies. We are undertaking to do this in an
overall proceeding with the cooperation of all those Federal
agencies who will have anything to do with plutonium. This
includes the AEC, the successor bodies, the NASA Department
of Defense, HEW, and all other people who are using plutonium
or transuranium elements. We have formed an interagency
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committee where these matters will be discussed and studied,
and determinations of what kinds of standards and who will set
them will be determined.
Through its Federal guidance authority, EPA has
responsibility for looking as an overview of plutonium as well
as setting generally applicable environmental standards. In
doing this, EPA will come forth and set standards, but we hope
that the philosophy that is used not only for EPA will be done
consistently across the board by all agencies involved.
Certainly EPA's standards will be EPA's standards promulgated
by standard procedures. However, we feel that this cooperation
between agencies which has already been demonstrated by the
hearings in Washington will lead to a straight-forward
proceeding where all matters can be taken.
Let me now introduce the Hearing Panel.
First, we have Walter S. Snyder: Dr. Snyder was
born in Mansfield, Ohio, and obtained his Ph.D. from Ohio
State University. He was a Professor of Mathematics at the
University of Tennessee for many years. From 1959 until quite
recently he held important posts with Union Carbide at Oak
Ridge. He is a specialist in internal dosimetry and a former
editor of Health Physics.
Melvin First: Dr. Melvin First was born in Boston
and received his Doctorate of Science in Industrial Hygiene
from Harvard. He has served with the Michigan uepartment of
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Health and is now on the faculty of the Harvard School of
Public Health. He is well known for his many contributions in
air and gas purification.
John Garner: Dr. John Garner was born in the
United Kingdom where he was educated, majoring in biochemistry
and received his doctorate in Veterinary Science at Liverpool.
After serving in several assignments in Africa and the United
Kingdom, he came to the United States in 1965. He served as
the Director of the Collaborative Radiological Health
Laboratory at Colorado State University from 1965 to 1972.
He is now Director of the Experimental Biology Laboratory of
the Environmental Protection Agency at Research Triangle Park
in North Carolina.
Karl Z. Morgan: Dr. K. Z. Morgan was born in
Kannapolis, North Carolina, obtaining his Ph.D. in Physics
from Duke University. He became Director of the Health
Physics Division at Oak Ridge National Laboratory in 1943. He
1s a member of the NCRP, as well as the ICRP, and is presently
the Neeley Professor in the Nuclear Engineering Department at
Georgia Tech.
Lauriston S. Taylor: Dr. Lauriston S. Taylor was
born in Brooklyn, New York, obtaining a Doctor of Science
degree from the University of Pennsylvania in 1960. He worked
at the National Bureau of Standards for many years starting
in 1927, becoming Chief of the Radiation Physics Division in
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-K- I
1960. He now serves as the President of the National Council
on Radiation Protection and Measurement.
Dr. William A. Mills: Dr. William A. Mills was born
in Lynchburg, Virginia, received his Ph.D. in Biophysics from
the Medical College of Virginia. He is a Commissioned Officer
U. S. Public Health Service, current, rank Scion List Director.
His past employment includes Oak Ridge National Laboratory,
the Southeastern Radiological Health Laboratory, Bureau of
Radiological Health, and is currently the Director of Criteria
and Standards Division, Office of Radiation Programs,
Environmental Protection Agency. His field of specialization
is the Bioeffects of Radiation.
Dr. Mills is the Chairman of the Panel, and he will
be the Hearing Officer for this meeting. Dr. Mills?
CHAIRMAN MILLS: Thank you very much, Dr. Rowe and
Mr. Green, for those opening remarks.
I need to take about a two-minute break here for
just a moment.
(Whereupon, a short recess was taken.)
CHAIRMAN MILLS: We are ready to resume.
On behalf of the Panel, let me welcome you to this
hearing. It is going to be a very long day, and we have got
a full schedule. We will run late this afternoon and into
the evening probably. I ask for your cooperation in abiding
by the procedures that have been established.
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Let me briefly review some of those procedures
which were announced in the October 24th Federal Register
notice for the hearing which we conducted in Washington. We
referenced those rules in the Federal Register notice of
December 24th, which pertained to this hearing.
The hearings will be conducted informally. The
technical Rules of Evidence will not apply. Discovery and
cross-examination of participants will not be permitted. The
Hearing Panel appointed by Dr. Rowe will consist of a
Chairman and three or more experts in the field of radiation
protection. The Panel will conduct the hearings. The
Chairman of the Hearing Panel is impowered to conduct the
meeting in a manner that in his judgment will facilitate the
orderly conduct of business, to schedule presentations by
participants, and to exclude materials which is irrelevant,
extraneous, or repetitious. In arranging this schedule,
persons wishing to present an oral statement shall give a
written notice no later than January 3, 1974, in order to be
placed on the agenda. The time allotment for such oral
statements shall be at the discretion of the Chairman, and
which shall not ordinarily exceed twenty minutes. Persons
wishing to submit written statements regarding the agenda
items may do so either in abeyance or during the hearings.
Such persons may also request an opportunity to request an
oral statement.
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Oral presentation may be presented by panel discussion
of technical experts chosen to present a particular viewpoint
if notice is given. The time allotment for such panel
discussion shall be at the discretion of the Chairman, which
shall not ordinarily exceed 60 minutes.
Requests at the time of the hearings for the
opportunity to make oral statements with no previous notice
shall be ruled on by the Chairman who is impowered to
apportion the time available, but not ordinarily to exceed fiv<
mi nutes.
Questions may be propounded only by members of the
Hearing Panel. I have requested that such questions be
submitted to Dr. Gordon Burley -- Gordon, will you stand?
(Whereupon, Dr. Gordon Burley stood.)
CHAIRMAN MILLS: For referral to the Panel for their
deci si on.
There was one other condition we had in the Federal
Register notice which in the public interest we have chosen
to eliminate, and that is the use of cameras and so on is
permitted only before and after the hearing and during the
inner recess, but not during the hearing session. We have
waived that procedural rule.
As Dr. Rowe indicated, a transcript of the hearing
will be made and a copy of the transcript, together with copiesj
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of all documents presented at the hearing, will constitute the'
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record of the hearing. A copy of the transcript of the
hearing will be available for public Inspection and 1n copy
within 30 days after the conclusion of the hearings today.
These will be available at the U. S. Environmental Protection
Agency. We will as soon as available get copies of such 1n
the Regional Office here 1n Denver.
With regard to the speakers, as I Indicated, we will
have a full schedule, and I ask for your full cooperation 1n
trying to make that schedule. To assist the Recorder and the
au.dience, I ask that the speakers and the Panel members avail
themselves of the microphone.
For those speakers who may have not registered to
participate, please Insure that Dr. Burley has a copy of your
full mailing address for these hearings.
With those remarks, I would now like to call on
Dr. William Burr from the Atomic Energy Commission In Washington,
D. C.
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Testimony By
William W. Burr, Jr., M.D.
Deputy Director
Division of Biomedical and Environmental Research
U.S. Atomic Energy Commission
Environmental Protection Agency
Plutonium Standards Hearing
Denver, Colorado, January 10, 1975
I am Dr. William W. Burr, Jr., Deputy Director of the Division of
Biomedical and Environmental Research, U.S. Atomic Energy Commission.
We appreciate the opportunity to participate in these hearings in Denver
as we did in the EPA hearings held last month in Washington, D. C. At
that time, the AEG presented approximately four hours of testimony which,
with questioning from the hearing panel, extended to nearly six hours.
Recognizing the interest and concerns of the people of the Western States,
and recognizing the fact that societal decisions of the type considered
in these hearings must be based at least in part upon scientific data,
we would like to review and very briefly summarize our testimony in
Washington.
This material covered the sources of plutonium and other transuranium
elements, control measures with respect to those sources, worldwide
environmental levels of these elements, biomedical effects observed to
date in experimental work, followup studies of exposed humans, and the
implications of all of this information with respect to radiation protection
criteria. In fact, it covered a great deal of factual information resulting
from scientific investigation. Although the entire hearing proceedings,
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including this testimony, is part of the public record, the AEC, in
order to make its testimony more readily available to interested persons,
has published the complete AEC testimony as a separate document. A
limited number of copies of this material are available here today for
the participants in today's hearings.
The hearing panel has already had extensive opportunity to question
those who presented the AEC testimony, and we have not requested all of
the speakers to be present today.
Dr. Liverman, in his introductory testimony, pointed out that concern
regarding plutonium is based upon several facts:
1) Increasing quantities of transuranics are being and will continue
to be produced as nuclear power provides a growing fraction of our national
energy requirements.
2) A number of these radioisotopes are similar to naturally occurring
alpha-emitting radioisotopes in that they have extremely long half-lives
and, once released, will persist and accumulate in the environment for
time periods extending over many human generations.
3) These naturally occurring alpha-emitting radioisotopes are known
to produce cancer of the lung, bone and liver in humans exposed to large
concentrations.
4) Comparable concentrations of alpha-emitting transuranic elements
are known to produce cancer of the lung, bone and other organs in
experimental animals.
These considerations make it mandatory that bioenvironmental health
and safety considerations be of primary concern with respect to activities
involving the production and use of the transuranic elements. More than
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thirty years of research have produced a substantial body of knowledge
and understanding regarding the health and safety aspects of such
operations. Through application of this knowledge, experience and
understanding, it has been possible to establish health and safety
procedures which have permitted many thousands of kilograms of plutonium
to be produced and processed, and we have yet to identify successfully
a major health consequence attributable to its radiotoxicity. This
record contrasts sharply with that for the commercial use of radium
earlier in this century where manufacture and use of a few grams of
material resulted in extensive occupational exposures and many cases
of cancer.
Meaningful judgments on the adequacy of current standards, criteria
and guidelines must be based in part on the knowledge and understanding
acquired in the course of nuclear development including the research
in the life sciences. This knowledge is extensive; Nuclear Science
Abstracts alone contains over 10,000 references on all aspects of
plutonium and other transuranic elements. These and other bibliographic
data are available at a number of sites throughout the country. Numerous
scientific meetings have been held to promote the exchange of information;
authoritative monographs are periodically prepared by those most competent
to do so.
This body of available information is continually analyzed by
various national and international groups including the International
Atomic Energy Agency (IAEA), the United Nations Scientific Committee on
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the Effects of Atomic Radiation (UNSCEAR), and various past and present
committees of the National Academy of Sciences; Biological Effects of
Atomic Radiation (BEAR Committee), Biological Effects of Ionizing
Radiation (BEIR Committee), and the current committee established to
examine the "hot particle" issue. It is also analyzed and used in
establishing exposure limits by organizations independent of any
governmental agencies. These organizations include the National Council
on Radiation Protection and Measurements (NCRP) and the International
Commission on Radiological Protection (ICRP). It is essential that the
objectivity which these organizations represent continues to be involved
in this process.
Despite the thousands of scientific references, information on the
biomedical and environmental behavior of plutonium and other transuranics
is not complete. Accordingly, the AEG continues to maintain a major
research program on the biomedical and environmental aspects of the
transuranics. This program focuses on those areas where additional
information is most likely to critically influence developmental programs,
operations and regulations. Such information is needed to make more
refined estimates of potential health and environmental hazards of
transuranium elements. The results of this research are published
regularly and are readily accessible.
I shall now very briefly discuss the several topics identified on
the slide; detailed information may be obtained from the AEC testimony
previously presented at the hearings in Washington.
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Since the discovery of plutonium there have been releases to the
environment; these have been reported. The overwhelming portion of
plutonium in the environment, over four hundred thousand curies, was
placed there as a result of military activities; some was also released
as a result of the burn-up of a space thermoelectric generator. If
releases due to military and space activities are not included, the
amount released as a fraction of what is handled is very small indeed.
For example, routine off-site releases during the six-year period
1967-1973 amounted to approximately 1.5 curies. We anticipate that
in the future releases from all government facilities through normal
discharge systems will not exceed 0.1 Ci/yr. That is, at present
release rates, less than three additional curies of plutonium will be
discharged to the environment by the year 2000.
I would like to mention at this time with respect to release
levels that the AEG operates under the "as low as practicable" philosophy,
and that values associated with "as low as practicable" have continually
decreased with increasing operating experience and improved control
technology.
Those few sites where releases and accidents have occurred are
extremely dissimilar in their environmental conditions, the physical and
chemical form of the radioisotopes involved and current and projected
land use. Our experience suggests that each of these may exert an
important influence on the practicability, including cost-effectiveness,
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of possible remedial actions. Since the number of contaminated sites
is small and is likely to remain small, and since these sites are so
diverse in character, it appears to be more effective to deal with
these situations on a case-by-case basis using current standards than
to attempt to develop additional standards and guidance generally
applicable to all of them. However, if additional guidance is developed,
it would be essential that it include the flexibility necessary to assure
effective application under widely varying circumstances.
The fact that plutonium has been dispersed into the atmosphere
provides us with a means of tracing globally distributed plutonium.
Monitoring studies have been carried out for many years, tracing the
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fate of this plutonium. These data were previously reported, along
with concentrations at a more local level in the vicinity of those sites
where releases have occurred. We continue to follow the transuranic
elements dispersed globally and to study the behavior of plutonium in the
quite diversified environments near weapons test areas in the United States
and the Pacific and around operating facilities in the United States.
Monitoring of the plutonium content of food, air, water and tissue
has been carried out to determine the relative quantity of that potentially
available which is finally incorporated into man. Based on a limited
number of tissue measurements, a very rough estimate of the total amount
of plutonium in individuals living in the United States is perhaps 3.5
picocuries or about 10 per person of that in the global biosphere.
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Many years of research and many millions of dollars have been
and are being devoted to understanding how plutonium is metabolized
by the body, what the ultimate biomedical effects of plutonium--and
other transuranics--might be, and what actions might be taken to
minimize those effects. These studies extend over decades and
include administration of a range of quantities of transuranic radio-
isotopes in a variety of chemical and physical forms to several animal
species by inhalation, ingestion and injection. These studies also
have provided direction for additional research, such as determining
the consequences of inhaling small quantities of aerosolized transuranics,
the effects of chronic inhalation exposures, and quantitating the effects
of "hot particles."
Although we are in a sense fortunate that so much of our biomedical
information thus far comes from experimental work, man is the primary
subject of our concern. Consequently, persons who have been occupationally
exposed to plutonium at some time in their careers are of particular
interest. Despite the fact that numerous persons have been occupationally
exposed during the past 30 years, to date there has been no serious health
consequence observed which has been successfully shown to be related to
plutonium. Some of these persons have been followed medically for nearly
30 years with periodic medical examinations.
What all of these data mean in the context of establishing environmental
and general public exposure limits was also discussed in the testimony. As
was pointed out there, man today is an evolutionary product evolved under
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24
constant exposure to radiation. In this process, man did not develop
means to insulate himself from either external or internal naturally
occurring radiation. Consequently, if additional exposures are kept
to a small fraction of that occurring naturally, our own development
and existence says that unacceptable biological risks would not be
anticipated.
This completes the summary. I wish to thank the Board for the
time to present this brief summary so that those not present at the
hearings in Washington might be aware of what was discussed in AEG
testimony, and, if they are interested, to avail themselves of the
opportunity to examine that portion of the record more closely.
In addition, since this part of the EPA hearings are in Colorado,
we feel that the Board might find it useful to have information on
the AEC's Rocky Flats Plant, which is northwest of Denver. A member
of the AEC staff, Mr. Earl Bean, Assistant Area Manager for Operations
at Rocky Flats, will present this material.
Should.the Hearing Board wish to direct any further questions to
the Atomic Energy Commission during or at the close of this hearing,
we will be happy to attempt to respond either orally, if we have the
information available, or in writing. To that end, we have a limited
number of staff and contractor personnel present.
-------
Testimony By
Earl W. Bean
Assistant Area Manager for Operations
Rocky Flats Area Office
U.S. Atomic Energy Commission
Environmental Protection Agency
Plutonium Standards Hearing
Denver, Colorado, January 10, 1975
Members of the Panel, Ladies and Gentlemen, I am pleased to have
the opportunity to present a very brief summary of the Rocky Flats plant
history, what is done at the plant, the effects of plant operations and
the AEC concern for health, safety and the environment.
Construction of the Rocky Flats plant was completed and operations
started in 1953. By the end of fiscal year 1974, the acquisition costs
for the plant totaled $222 million. This' includes about $91 million for
equipment and $131 million for land, buildings and facilities. Over 90
major structures containing approximately 1.7 million square feet of
building area are included on the plant site. About 2900 people are
employed at the plant. The plant is situated on about 2500 acres of
Government owned property approximately 15 miles north and west of Denver.
The Government has purchased approximately an additional 4000 acres around
the perimeter of the original plant site to act as a buffer zone in order
to minimize the types of problems which often arise from the proximity of
industrial facilities to residential communities.
The plant is part of the AEC nuclear weapon production complex. It
has been operated from the onset by the Dow Chemical Company. Effective
July 1, 1975, Rockwell International Corporation will operate the plant.
-------
The primary function of the plant includes metal working and chemical
recovery. Plutonium is one of the primary materials handled at the
plant. Since the plant operation began, extensive control techniques
have been utilized to insure that plutonium in liquid and gaseous
effluents leaving the plant site are below allowable standards and at
the minimum practical level. Improvements have continually been made
in these control techniques so that plutonium concentrations in air and
water leaving the plant site have been reduced and have been substantially
below currently accepted concentration guides.
Small amounts of plutonium have been released in the air and water
due to normal plant operations and due to accidental releases. Two
major fires occurred at the plant site, in 1957 and 1969, during which
small amounts of plutonium were released. Essentially all of the off-
site contamination resulted from the plutonium released over a period
from 1958 to 1968 due to leakage from 55 gallon drums containing plutonium-
contaminated lathe coolants. Soil samples have been collected both on
and off-site to describe the distribution and amount of plutonium from
the plant. These findings have been published and can be made available
to the Panel. We will be happy to answer questions concerning these
areas or any other area of local concern.
An extensive environmental monitoring program is conducted to insure
that all plant discharges are well within applicable AEG and EPA standards.
Air, water and soil are routinely and repetitively sampled and analyzed
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27
for plutonium within the plant site, at the plant boundary, and in the
communities surrounding the plant. All water discharged from the plant
is held in ponds on the plant site and analyzed prior to release.
In addition, vegetation and wildlife are sampled periodically and
analyzed for plutonium. The results of the environmental monitoring are
reviewed monthly with the EPA, Colorado Department of Health, and other
state and local officials. These data are published semi-annually.
Background radiation measurements are made at various locations up
to 20 miles from the plant. The maximum measured background concentrations
of plutonium in water was .03% of the maximum allowable levels. During
1974, the average plutonium concentration in water leaving the plant site
was .05% of the standard. In the same year, plutonium in Great Western
Reservoir, which is the drinking water supply for the city of Broomfield,
averaged .0027o of the standard. The maximum measured background concen-
tration of plutonium in air was 0.4% of the maximum allowable concentrations.
In 1974, the plutonium in the air at the downwind site of the buffer zone
was less than .4% of the currently accepted standard and plutonium in the
Broomfield air averaged .4% of the standard. Both values are the same
as found for background. In general, plutonium concentrations in plant
effluents have been less than 1% of the allowable standards.
In addition to monitoring the surrounding communities, an extensive
monitoring program is conducted at the plant. This piogram includes
monitoring the air in all of the work areas; multiple samplers and
-------
continuous alarms at gaseous release points; periodic soil, vegetation
and animal analysis; monitoring of ground water through a series of wells;
employee monitoring, and periodic employee health examinations. An
extensive quality control program is included as part of all monitoring
activities.
Several long term research studies are under way to determine the
movement and effect of plutonium in the eco-system. Several studies are
being conducted by the University of Colorado and Colorado State University
to understand the behavior of plutonium in the aquatic and terrestrial
environment. Other studies conducted by the USGS, AEC laboratories, and
private consultants have been concerned with resuspension and disposition
of plutonium, the meteorology of the Rocky Flats area, and possible move-
ment of plutonium through ground water and soil. In addition there are
data available from extensive environmental studies of plutonium which
have been conducted elsewhere; this information is being utilized to the
degree it is applicable to the Rocky Flats areas.
In the past several years significant improvements have been made
to the physical facilities and operations in the areas of environmental
protection, fire safety, occupational safety, and handling of radioactive
wastes. These include:
--Improved packaging of solid radioactive wastes.
--100 specific improvements to plant fire protection as recommended
by an outside consulting fire protection association.
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29
--A new waste treatment facility which, when completed in 1976,
will recycle all process waste water.
—A new tertiary treatment facility for sanitary sewage to comply
with the most restrictive state and EPA standards for water
quality.
--A new plutonium recovery facility which is being constructed
to stringent design criteria for new plutonium handling facilities.
--An expanded environmental monitoring and sampling program.
In summary, the AEG is aware of the environmental aspects of its
Rocky Flats operation and continuously monitors the effluents (both air
and water) that leave the plant site. Actual releases measured are
substantially below existing standards.
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?0
Thank you.
Chairman Mills: Mr. Bean, I have a quick question and
the Panel may have some also.
This recent purchase of land surrounding the Rocky
Flats Plant, can you say something about what this land has
been used for in the past, and what you propose to do with
it from the standpoint of controlling access to the land
itself?
Mr. Bean: The land in the past has been strictly
agricultural, principally grazing. We certainly have no
plans to do any development on the land. It will be held
as an undeveloped buffer zone around the plant site.
Chairman Mills: Does the Panel have any questions?
Dr. First?
Dr. First, First, I am sure this will be clear when I
get your written comments. But, we went through a lot of
numbers in a hurry, and I am a little confused. Perhaps you
might clarify the relationship between the measurements in
the environment, which I gather from your discussion are at
or close to background, and the relative percentage of
allowable emissions as measured in the stacks, etc., and
water discharges from the plant. Can we relate those two
figures in any way?
Mr. Bean: Your question is concerning the amount in
the stack versus what is in the background air?
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31
Dr. First: No, is the percentage of emissions from
your measured effluents in the same relation as the environ-
mental measurements to background?
Mr. Bean: Dr. Milton Thompson from Dow Chemical is
present. Milt, why don't you come up and use the micro-
phone?
Dr. Thompson: Let me try from here. I am not sure I
understand the question, but the releases from our plant at
the plant boundary in general are like 1% or less than the
currently allowable standard. Now, that is true for both
air and water at the plant boundary. The measurements in
the communities near the plant are essentially background
measurements.
Dr. First: As I understand, you are saying that you
are measuring environmental concentrations at the plant
boundary. My question referred to the measurement in the
effluent streams before release into the environment?
Dr. Thompson: The material in the effluent stream
leaving the plant site, whether it is water or air, are in
general less than 1% of the currently allowable standards.
Dr. First: Thank you.
Dr. Taylor: By way of perspective, I would like to ask
Dr. Burr if he could tell us approximately how much natural
alpha-emitting radioactive material do we find in the normal
environment? You mentioned that we will get 0.1 curies, a
-------
tenth of a curie per year emitteed from the AEC operation.
Do you happen to know roughly the amount of alpha-emitting
radioactive material per square mile of earth a foot deep,
let us say?
Dr. Burr: I do not have the figure, Dr. Taylor, at
hand. We certainly can supply it, or perhaps you could
supply it?
Dr. Taylor: I will supply it. It is of the order of
one curie of radium and several curies of the -- I think it
totals something a little bit less than 10 curies of the
alpha-emitting part of the radium series per square mile a
foot deep. (Note: see letter from Dr. Taylor at the end of
the questioning.)
Dr. Snyder: I would like to ask a question of Mr.
Bean. Does your monitoring program include monitoring for
foodstuffs that might reach human consumption, and are we to
infer that the levels seen in these, perhaps milk or meat or
brook trout, I am not sure, are comparably small to what
your effluent releases are?
Mr. Bean: I think the answer is generally that that is
true - the same order of magnitude as our effluent releases
are. We have done some aquatic studies on minnows in the
stream. We do not have large rivers, we just have very
small streams that have some minnows living in them. There
does not seem to be any concentration mechanism in those
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33
minnows. The levels in them are --
Dr. Snyder: Second, may I ask, could you summarize
very briefly the experience on transportation of these
things, the plutonium particularly, from the plant? Have
there been a significant number of accidents in which there
was breach of containment or at least threatended?
Mr. Bean: So far, in our transportation experience
with both the plutonium material coming to the plant and the
product leaving and the waste material, we have never had an
accident, transportation accident, that I know of where
there has been any release of material.
Dr. Morgan: I would like to ask Mr. Bean first, you
indicate that in general the releases have been less than II
of the allowable levels. How much plutonium do you allow,
that is what is the allowable level for plutonium per year
in curies?
Mr. Bean: I do not know the number offhand. We use
the per cubic meter standard for air and the per liter
standard for water, and we would have to -- how about you,
Dr. Thompson? Do you know the exact number?
Dr. Thompson: I do not have the total allowable
number, but the standard that we use is the most restrictive
standard for the general population which for air is .02
picocuries per liter, for water is .1667 picocuries per
liter.
-------
Dr. Morgan: My question I think implies, we would be
concerned about the total number of curies released with a
long half-life in addition to the concentration in the air
and water?
Dr. Thompson: I think we can provide you with that
number, but we do not have it now.
Mr. Bean: We can give you our annual environmental
monitoring reports which have those numbers in them; we will
provide those to the Panel. (Note: material is attached to
the end of the questioning.)
Dr. Morgan: I have a question of Dr. Burr. I believe
you indicated that there would be less than three additional
curies of plutonium released from all Government facilities
to the environment by the year 2000. I have then three
comments on this, or questions. First of all, does this
include the releases by plant accidents? Second, does it
include releases by accident with military planes? We have
had two such accidents that have been widely publicized.
Third, does it include releases of all plutonium? You said
that for plutonium there would be more Pu-241 and 238. Does
it include the others too?
Dr. Burr: First of all, let me address the accident.
This is from routine release and not accidental releases; it
does not include accidents.
Dr. Morgan: This is assuming that you have no accidents
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35
in this period?
Dr. Burr: That is assuming there is not an accident.
Dr. Morgan: What about the military?
Dr. Burr: Likewise for the military. In regard to
whether it includes all the transuraniums, I would like Dr.
Yoder to comment on that.
Dr. Yoder: It includes all of the plutonium isotopes.
Dr. Morgan: And the military, does it include all of
that?
Dr. Yoder: No, sir.
Dr. Garner: Is that figure predicated upon the develop-
ment of a fast breeder program?
Dr. Burr: I would like Dr. Yoder to respond to that.
Dr. Yoder: I did not hear the question.
Dr. Burr: Is this predicated on the development of a
fast breeder? Do we have a figure?
Dr. Yoder: I think it does, yes.
Dr. Burr: We believe it does, but we can verify that.
Dr. Morgan: Does this include the MOX Program, mix
oxide uses in light-water reactors?
Dr. Burr: This is a part of Dr. Yoder"s Washington
testimony; that is why I am referring to him. I would like
Dr. Yoder to respond to that. Dr. Yoder?
Dr. Yoder: Those numbers refer to AEC plant operations,
those operations in Government facilities. MOX, if it is
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p6
done at commercial facilities, is not included in those
numbers.
Dr. Morgan: So Barnwell operations, if they get in
operation, will not be included, although this may be the
principal contributor to the environment?
Dr. Yoder: That is correct, Barnwell is not included.
Chairman Mills: Mr. Bean, for the record, we would
like to have a copy of your annual monitoring report.
Mr. Bean: We will be pleased to provide them for the
past 4 years. (Note: Material follows.)
Chairman Mills: Thank you, Dr. Burr and Mr. Bean.
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National Cdurx H on Radiation Protection -7
and Measurements
7910 WOODMONT AVENUE, SUITE 1016, WASHINGTON, D. C. 20014 AREA CODE (301) 657-2652
LAURISTONS TAYLOR, Prrvdent
E DALE TROUT, Vice President
W. ROGER NEY, Executive Director
January 22, 1975
Dr. William Mills
Director
Division of Criteria and
Standards (AW-560)
Radiation Office
Environmental Protection Agency
Waterside Mall, E-635
401 M Street, S.W.
Washington, D.C. 20460
Dear Bill:
You may recall that during the hearings, I questioned Dr. Burr
about the amount of naturally-occuring radioactive material in the
soil of the earth. When he did not know the answer, I provided it,
but I have now discovered that I was grossly incorrect in some of
the numbers that I gave him. Since I believe this is important to
the overall hearings, I would like to have the material below in-
cluded as a correction statement.
The average concentration of some radioactive materials in the
earth's soil is as follows:
Uranium — 2 x lO"-"^ curies per gram
Thorium — 1.3 x 10~-*-2 curies per gram
Radium — 2 x 10~12 curies per gram
As to actual amounts of radioactive material, the following
quantities would be contained in a surface of earth 1 foot thick and
1 mile square:
i
Radium — 1 gram
Uranium — 3 tons
Thorium — 6 tons
In addition to these materials, there are varying amounts of
carbon-14 and potassium-40.
The source of this information and the references are contained in
"Radiation Hygiene Handbook," by H. Blatz, page 4-7 (1959).
Sincerely yours,
Lauriston S. Taylor
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ROCKY HATS LMERCPAVY PREPAREDNESS PROGRAM
It is the policy o* th" AEC* to develop aid maintain appropriate Emergency
Preparedness Programs for each of its facilities. Rocky Hats has a
comprehensive emergency program which is integrated and coordinated with
the EiVifii gency Preparedness Programs of other Federal, state, and local
governmental agencies. The program is designed to cope with all types of
emergencies which might involve tha plant. These include radiological.
operational, natural, civil and national disasters or emergencies. The
responsible agencies, including the AEG, have both written and informal
plan? which cover those emergencies which occur on-site hut have an effect:
off-site, as well as off-site emergency situations which may have an effect
on-site. It is these plans which comprise the Rocky Flats Emergency Pre-
paredness Program. The program provider for the systematic, orderly
handling of emergencies in such a manner as to minimize any adverse
effacts v/h:ich could result from them. Lines of authority are delineated
and responsibilities for immediate and continuing action are assigned to
specific agencies and individuals. Emergency procedures and action levels
are established and clearly stated. -Response team rosters and 24 lu;ur
radio and telephone contacts are maintained in a current status. Repeated
test exercises and real time experience have demonstrated the effectiveness
and capability of these response forces.
The principal agencies whose emergency plans make up the Rocky Hats
Emergency Preparedness Program are the Office of Preparedness; the
Defense Civil IVeparedness Agency; the Interagency Radiological Assistance
Committee; the Atomic Energy Commission; the Federal Bureau cf Investiga-
tion; the State of Colorado Health Department; the State of Colorado
Department of Military Affairs, Civil Defense Division; the counties of
Jefferson, Adams, Boulder, Arapahoe; and, the communities of Broumfielci,
Boulder, Golden, and Denver. The recognition by these Federal., state,
and local agencies of their involvement in the Rocky Flats Emergency
Preparedness Program can best be indicated by a synopsis of their plans.
FEDERAL
The Office of Preparedness and the Defense Civil Preparedness Agency have
the overall responsibility for civil defense and survival in the event
of enemy attack, major natural disaster; or catastrophic man-caused
emergency. They plan the response training, warning systems, evacuation,
shelter, care, hospitalizarion. feeding and rehabilitation of the com-
munity following -3 disaster. Exercise? are held testing coordination
between governmental agencies, communications, response efforts, facilities.
transportfitirir, logistics, criticc:! supplies and the lilct. Tiid Kfcj,it/u o
To avoid confusion the AEC is referred to throughout this paper. However,
effective January 19, 1975, the AEC was abolished by PL 93-438 and its
functions transferred to two new independent federal agencies, the Energy
Research and Development Administration (ERDA) and the Nuclear Regulatory
Commission. The Rocky Flats plant is under ERDA'a jurisdiction.
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39
- 2 -
Headquarters for DCPA is located in a hardened underground facility at the
Denver Federal Center. By agreement between the AEG, the DCPA, and OP,
the AEG Area Office at Rocky Flats has assigned liaison representatives
to this Regional Emergency Operating Center as the official AEG representa-
tives at the Region 8 Federal Relocation Center. Continuous liaison is
maintained between these federal agencies and in the event of national
attack, a severe natural disaster or emergency involving Rocky Flats, AEG
will have representation at that facility for the duration of the emergency,
arid coordinate any response and assistance efforts related to the Rocky
Flats Plant. The Regional Office has been thoroughly briefed on the
Rocky Flats operation and has the authority and responsibility to assist
both the plant and the community in the event of any major disaster in-
volving Rocky Flats.
The Interagency Radiological Assistance Plan of 1961 provides that each
of the twelve signatory Federal government agencies will assist one
another in the event of a radiological incident. The agencies are the
AEG, Department of Agriculture, Department of Commerce; Department of
Defense; Department of Health, Education, and Welfare; Department of Labor:
Department of Transportation; Environmental Protection Agency; Interstate
Commerce Commission; National Aeronautics and Space Administration; Defense
Civil Preparedness Agency; and the Postal Service. The AEG coordinates
response activities under the plan and in the event of a serious emergency
at Rocky Flats, almost unlimited technical and logistic assistance could
be obtained from the participating agencies.
The Atomic Energy Commission has a Radiological Assistance Plan which
assigns nationwide and regional responsibilities, establishes lines of
communication, identifies resources, and provides general guidance for
the handling of radiological accidents. The objectives of the plan are:
a. To develop and maintain plans, resources, guidelines, arrangements,
and procedures necessary to provide a ready capability to respond
effectively to radiological emergencies', including cooperation and
coordination with other agencies as needed.
b. To make radiological assistance available when the AEG believes it
is needed or when requested by anyone cognizant of an incident
suspected to involve the misplacement or loss of control of:
(1) source, byproduct, or special nuclear materials;
(2) ionizi n^ T£I d i -i t ~> op prnj-j-coQ T.iVio^-o £>uch sources have been n"cd
in connection with AEc-nupportecl work, including radium and
other naturally occurring radiormclides and particle accelerators
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40
_ tD _
c. To encourage Srate and local governments, private indnstry, and
other organizations to develop thf-':r own radiological emergency
capabilities and plans Tor coping with radiological incidents.
Rocky Flats is located in Radiological Assistance Region 6. The Idaho
Tails Operations Office is the Kon,ionn! Coordinating Office for Region 6.
In the event of a radiological emergency at Rocky Flats the total resources
of the AEC and its contractors could be called upon under this plan. The
plan and implementing instiuctions issued by Idaho have been coordinated
with representatives of the State of Colorado.
As the result of a "Joint Department of Defense and AEC agreement in
Response to Accidents Involving Radioactive Material," dated May 9, 1966,
the AEC and the DOD have agreed to mutually assist one another in the
event of an accident involving radioactive materials. To provide such
assistance they have established a Joint Nuclear Accident Coordinating
Center. Located in Albuquerque, New Mexico, this facility is manned by
the AEC and the DOD. Records are maintained of the specialized capa-
bilities and equipment of each agency, wherever located, which could be
used in the event of an emergency. The center is manned 24 hours a day
and has telephone contacts with over 300 AEC and DOD radiological assis-
tance teams. In the event of a radiological accident at Rocky Flats,
these teams are available through the JNACC to provide whatever
assistance is appropriate.
STATE
The State of Colorado has a "Radiological Response Plan for Fort St. Vrain
Nuclear Generating Station and Rocky Flats Plant." This plan provides
notification channels in the event of an emergency involving possible
off-site contamination and for mutual evaluation by AEC arid the Colorado
State Department of Health of what action should be taken to protect
public health and property in the event of a release.
The State of Colorado Department of Military Affairs, Civil Defense
Division has developed a "Rocky Flats Plan" for operating procedures in
the event of a radiological incident at the Rocky Flats Plant. It yets
forth the responsibilities of the AEC's contractor at Rocky Flats, the
Colorado Department of Health, the State Civil Defense Division of the
Department of Military Affairs, the Jefferson County Sheriff, and the
Radiological Assistance Teams of the AEC. Tbr nlan provides for the
Emergency Operating Center of the State Civil Defense to effect emorgencv
nnrif~:r^^ions Lv luu '.-taLu ci^enclua that Flight be affected. Coir.rr.unicari uu
channels are listen for the EOC, the State Health Department, the
counties of Adams, V.onlder, Jefferson, and Denver City and County. Tnr,k
assignment? are established for each organization should an emergency duvw'inp.
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41
- 4 -
The "City and County of Denver Response Plan for a Rocky Flats Plant
Incident" further specifies the responsibilities of various departments
and offices under these political entities in case of off-site contami-
nation resulting from an incident at the Rocky Flats Plant.
The Metropolitan Emergency Telephone System (METS) is a private line
telephone connecting the State Emergency Operating Center with the Office
of Civil Defense, National Warning Centers and State wanning points, with
additional outlets at Rocky Flats and AEC offices, and municipal fire
departments, weather bureaus, and emergency operating centers. A ring-
down circuit exists which immediately signals all the subscribing
parties.
A plan for the care of Radiation Accident victims at the University of
Colorado Medical Center has been developed and is in draft form. ]t
provides guidance for any area organization which may have need to send
a patient to the center for treatment following exposure to radioactive
materials in those instances where the injuries which attend the exposure
cannot be treated at the Plant.
.*•
Dow" has discussed these procedures with representatives of the Colorado
General Hospital and the parties concluded that the procedures would
provide the required medical services in the event of an accident at
Rocky Flats as the result of which injured persons were contaminated.
LOCAL
The State of Colorado Department of Military Affairs Civil Defense
Division Rocky Flats Plan mentioned above directs the participating
government agencies: Boulder County, Adams County, Denver City/County,
Jefferson County, State Health Department, Colorado State Patrol, and
the Rocky Flats Plant to develop emergency plans consistent with the
Department of Military Affairs Plan. Numerous meetings and orientation
tours of the plant site have been held with representatives of various
political entities. Emergency communication channels have been
established and the responsible individuals identified in each agency.
Although formal written plans have not been formulated in every case,
an understanding of the responsibilities of each agency has been achieved.
There is a good spirit of cooperation among county and community officials
regarding site emergency preparedness.
* Tho vov Ch?nrjca1 Company, Kocky Mats Division, is currently
AEC's operating contractor at the Rocky Tlats Plant.
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42
THE ROCKY FIATS PTAN'S
A most significant part of the Rocky riats Emergency Preparedness Program
are the emergency plans prepared by the AEC's Rocky Flats Area Office and
the AEC's contractor at Rocky Flats. The "Emergency, Defense, and Mobili-
zation Plan for Rocky Flats" is one of the principal documents. It-
expresses the basic philosophy of Rocky Flats Emergency Plans that the
plant should be self-sufficient in the handling of on-site emergencies.
The objectives are: (1) to take necessary measures to prevent any
disasters that can possibly be averted; (2) to mitigate the effects of
a disaster, and (3) to specify plans and to provide guidelines for
actions to be taken in an emergency.
Other Rocky Flats Emergency Planning documents are as follows:
Emergency Manual - Dow Rocky Flats Division
This manual contains information- to be used in the event of a plant-
wide emergency such as fire and/or explosion; on-site major radioactiv
contamination; on-site release of chemicals, gases, or toxic
materials; on-site hazardous chemical, radioactive, or oil spill
which may be discharged off-site via waterways; transportation
accident; on-site criticality emergencies; mass casualties and
serious injuries; sabotage; major structural failure; bomb threat;
civil defense; civil disturbance; forces of nature; utilities
interruptions; and telecommunication failure. The manual has a
section on each of the above emergencies which includes an immediate
action checklist to be used during the emergency. In addition to
this checklist, the section includes a description of the alarms
signaling the emergency, a brief discussion of the emergency, and
references for additional information.
Response Plan for Accidental Discharge of Oil or Hazardous Substances
This document outlines the actions to be taken in responding to
accidental discharges of oil or hazardous substances on the plant
site.
Building Rules for Process Area Buildings
Each manua? contains a large section called, "Emergency Procedures."
This section discusses each type of alarm system, v.'hat each indi-
cates, and what typo of action is required. It gives pruceuaieS i_ur
emergency shutdown and for actions to be undertaken in civil defense
or disaster situations.
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43
- 6 -
Communications
Communications play a vita!) role in emergency planning. Systems
available to the plant are:
National Warning System (NAWAS), Metropolitan Emergency
Telephone System (METS), two-way radio system with Jefferson
County Sheriff's Department, monitoring capability of the
Colorado State Patrol radio frequency, and AEG radio frequencies
operable throughout the Metropolitan area. The METS capability
permits immediate contact between the greater Denver area
emergency organizations and offices such as the Governor's
office and the State of Colorado Emergency Operating Center.
In summary, it seems clear that a satisfactory emergency preparedness
program exists in connection with the Rocky Flats facility. Plans and
procedures to cope with natural and operational hazards have been
developed and coordinated between all responsible agencies. These include
Federal, State, and local government plans, as well as plans developed
at the Rocky Flats Plant.
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TABLE
RADIOACTIVE MATERIALS RELEASES FROM ROCKY FLATS
Loss Mechanism
Airborne
Year
1953
19-54
1955
1956
1957
1958
1959
I960
1961
1962
1963(<
1964(<
1965((
1966
1967
1968
1969
1970
1971
1972
1973
1974
238n
(b)
38
51
34
58
523
368
= ) 339
~) 236
^ 277
143
139
138
167
190
58
42
63
30
1975 (Est- 30
imated)
Total
(thru
1974)
2898
235
127
230
308
540
863
483
249
277
193
186
233
112
161
51
64
41
4
11
10
10
4143
(a)
Pu
1.5
65 . ,
72
229
270
3144
1435
1321
1457
2974
3903
230
6518
323
397
488
718
379
74
59
77
1000
1000
25085
Waterborne
1126
1226
1099
1653
1863
2796
5800
5900
6110
5500
2360
2620
2630
4227
2765
2982
4384
3369
6723
10412
8990
1800
1800
87335
TOTAL
(a,b)
Fires
Spills
18,000
500,000
(d)
880
18,88b 500,000
638,341 uCi
-------
TABLE
(Continued)
(a) All results were obtained from monitoring for total long-lived alpha
emitters prior to mid-1973. The specific isotopes listed refer to
predominant material processed in various areas. From mid-1973
to present, nlutonium releases are from specific isotopic analyses
for*2"3"8puff2439Pu"and2"4Opu.
(b) Buildings 444-447 began operations in 1956 and should be included
in the 3°U colurnn. Howe'ver^ results of monitoring do not become
from this area until I960.
2 o c o o c
(c) Records of total uranium releases did not separate " U and U
from 1963-1965. Results reported here are derived from approximate
ratios from other reporting periods.
(d) Beginning in July 1958, a drum storage area was established. From
that time until November 1969, when an asphalt cover was completed,
it is estimated by Rocky Flats sampling that 0. 5 Ci of plutonium was
lost off site resulting from leakage of these drums. HASL report
849 estimates 3. 06 Ci as the amount lost from the spills. The
difference in estimates results from use of larger areas in the HASL
calculations.
-------
-------
PREVIOUSLY PUBLICLY RELEASED
November 1, 1971
SEMIANNUAL REPORT:
ENVIRONMENTAL SAFEGUARD '71
RADIOACTIVE MONITORING AND ENVIRONMENTAL SURVEILLANCE
JANUARY THROUGH JUNE 1971
Protective measures and radioactive levels
in the vicinity of the Rocky Flats Plant,
Golden, Colorado
Research & Ecology
Health Physics
DOW CHEMICAL U.S.A.
Rocky Flats Division
-------
-------
November 1,1971 RFP-ENV-7
Publication Date
SEMIANNUAL REPORT: ENVIRONMENTAL SAFEGUARD 1971
Radioactive Monitoring and Environmental
Surveillance, January Through June 1971.
Protective measures and radioactive levels
in the vicinity of the Rocky Flats Plant,
Golden, Colorado
M. R. Boss
L. M. Steward
Prepared by Product and Health Physics Research and
Ecology Group, Rocky Flats Division, Dow Chemical U.S.A.
S. E. Hammond, Industrial Hygiene and Bioassay
J. R. Seed, Director; Product and Health Physics Research
J. F. Willging, Director; Research and Ecology
H. E. Bowman, Assistant General Manager for Operations
L. M. Joshel, Rocky Flats Division General Manager
DOW CHEMICAL U.S.A.
ROCKY FLATS DIVISION
P. 0. BOX 888
GOLDEN, COLORADO 80401
Prepared under Contract AT(29-1)-1106
for the
Albuquerque Operation? Office
U. S. Atomic Energy Commission
-------
-------
RFP-
ENVIRONMENTAL SURVEY - JANUARY - JUNE 1971
i
Dow Chemical U.S.A.
Rocky Flats Division
Post Office Box 888
Golden, Colorado
80401
The Rocky Flats Division of Dow Chemical U.S.A. is
located approximately 16 miles northwest of downtown
Denver. The Government-owned reservation occupies
about 2600 acres. The inhabited portion of the plant,
occupying about 425 acres, is located in the center of
the property.
Primary controls are exercised at the emission source, i.e.,
stacks for airborne contaminants, and at the process
waste treatment plant for liquid effluents. Ideally,
emissions are controlled to below the recommended con-
centration guide levels for the general population, regardless
of dilution from external sources.
The environmental survey data contained in this report
have been released on a monthly basis to the Colorado
Department df Health.
STACK EFFLUENT SAMPLING
The exhaust -ducts in the buildings engaged in operations
involving processing of radioactive material are continu-
ously monitored using isokinetic* sampling techniques.
The samples are analyzed for total long-lived alpha activity.
The total activity released to the atmosphere is calculated
from the total effluent volume. Table 1 summarizes both
the plutonium and uranium stack sampling results.
The most restrictive concentration guide for plutonium
in air is 0.06 X 10."'2 n Ci/ml averaged over one year to
an individual in the general population. The measured
concentrations from the plutonium operations, including
natural long-lived alpha activity, average 0.011 X
ID'12 ** M Ci/ml or 18.2% of the standard.
The most restrictive concentration'guide for uranium
in air is 3 X 10"'2 n Ci/ml averaged over one year to
an individual in the general population. The measured
concentrations from the uranium operations, including
natural long-lived alpha activity, average 0.011 X-
10"'s t or 0.4% of the uranium standard.
AIR SAMPLING
Air filters from 12 on-site air-monitoring stations,
sampling at 2 fts/min, are collected and analyzed daily
for total long-lived alpha concentrations. Table 2
summarizes these air sample results. The concentrations
reported include activity due to natural long-lived alpha
emitters.
Air samplers programmed to sample 10 min. each hour are
located in Boulder, Broomfield, Coal Creek Canyon,
Denver, Golden, Lafayette, Marshall, Wagner Site, and
Westminster (see map). These air filters are collected
weekly and are analyzed for total long-lived alpha activity.
These air sample results are Tabulated in Table 3 and also
include activity due to natural long-lived alpha emitters.
The on-site concentrations range from 0.0041 X
10- ' 2 ju Ci/ml to 0.0323 X 10 '' J u Ci/ml, while
samples collected off site show a range of concentrations
from 0.0035 X 10'1S fiCi/ml to 0.0185 X 10'12 juGi/ml.
*Au* moving into the sample tubes is at the same velocity as
that inside the duct being sampled. This prevents turbulence at
the mouth of the sample tube and provides better trapping for
paniculate matter.
"Monthly average of total emissions from all Pu Operations
during reporting period.
An additional network of 12 high-volume air samplers began
operating on February 1 1, 1971. These samplers are located
2 to 3 miles from the plant perimeter. Samples are collected
on a 4-inch-diameter filter paper at an average flow rate of
18 ft3/min. The air filters are collected daily, composited
into a weekly sample and analyzed specifically for plutonium.
Sample volumes typically average about 5000 m3. Additional
high-volume samples of 4-6 hours duration are collected each
week from Wagner Site (S-18), located 2.5 miles southeast of
the plant and Coal Creek Canyon (S-l 1) 3 miles west-
southwest of the plant. These samples vary in size but
average about 200 m3 . Table 4 summarizes the plutonium
concentrations found in the high-volume air samples. For
tMonthly average of total emissions from all uranium operations
during tha reporting period.
-------
RFP-ENV-71A
convenience in reporting, monthly averages are given for
each sample location. The concentrations from the air.
sampling network range from 0.00006 X 10~' 2 juCi/ml to
0.00267 X 10~' 2 nCi/ml. Samples collected from Wagner
Site and Coal Creek Canyon show somewhat higher con-
centration levels. The concentrations shown in Table 4
are influenced by the sample size and indicate the
particulatc nature of the plutonium being collected. The
concentrations found in the large-volume air samples are a
better indicator of possible chronic exposure levels.
DUSTFALL SAMPLING
Dustfall sample collection trays are mounted on all the off-
site, low-volume air sample stations. Sample collection
trays are also located at standby stations in Arvada, Eastlake,
and Superior. Dustfall samples are collected bimonthly
and analyzed specifically for plutonium content. Dustfall
samples from Castle Rock and Berthoud are collected
less frequently. The results, which include plutonium
fallout from atmospheric weapon testing in addition to
plutonium of plant origin, are summarized in Table 5.
There are no established concentration standards for
plutonium in dustfall. The values reported are of the
same order of magnitude as are reported for plutonium
from worldwide fallout.
WATER SAMPLING
The Rocky Flats plant is drained by three streams that flow
through the reservation; North and South Walnut Creeks
located north of the plant, and Woman Creek to the south.
Treated sanitary and process waste waters are released to
South Walnut Creek through a series of four holding
ponds. Effluents released through the sewage treatment
plant meet the Water Quality Standards for Colorado and
the U.S. Public Health Service Drinking Water Standards
(1962). The overflow from the pond system flows into
Great Western Reservoir. Flow into Great Western Reservoir
from Walnut Creek is comprised largely of liquid wastes
from the plant. Holding ponds located on North Walnut
Creek and Woman Creek also exist; however, no effluents
are discharged directly into these ponds.
Daily water samples are collected from the holding ponds,
composited into a weekly sample and analyzed for gross
alpha (uranium plus plutonium) activity. The plutonium
contribution to the sample activity is measured by alpha
spectrometry. Daily chemical analyses are also performed
on these water samples. Table 6 summarizes the results of
the holding pond analyses. Gross alpha concentrations
range from 4.58 X 10"9 to 36.64 X 10~9 juCi/ml. Plutonium
concentrations range from 0.25 X 10~9 to 7.23 X
10~9 /iCi/ml. The gross alpha concentrations reported in
Table 6 include naturally occurring uranium activity.
Water in use at the Rocky Flats plant is obtained from
Ralston reservoir. Water samples collected at the reservoir
range up to about 29 X 10~9 pCi/ml in gross alpha
activity as shown in Table 8. Some degree of decontami-
nation of liquid waste effluents released to the holding
ponds is affected in the sewage treatment plant. Guides
do not exist for gross alpha concentrations in water. The
recommended concentration guide for soluble plutomum-239
in water is 5 X 10~6 /jCi/ml averaged over one year to
an individual in the general population. This concentra-
tion guide is 100-1000 times greater than the gross alpha
concentrations reported in Table 6. Total activity
released to Walnut Creek via liquid effluents is based on
flow rates through the holding ponds.
Tap water samples from the surrounding communities
and water samples from the major reservoirs in the area
are collected bimonthly. Tables 7 and 8 summarize the
tap and reservoir water sample results. Plutonium analyses
are made on the sample if sufficient gross activity is present.
Concentrations in tap water samples reported in Table 7
range from 0.11 X 10'9 to 18.58 X 10~9 fiCi/ml for
gross alpha activity. Concentrations in reservoir water
samples range from 0.26 X 10~9 to 28.79 X
10"9 ptCi/ml for gross alpha activity.
Weekly grab samples from Walnut Creek, below the con-
fluence of the north and south branches, are analyzed for
gross alpha and plutonium activity. Gross alpha con-
centrations in Walnut Creek average 11.71 X 10~9 pCi/ml
while plutonium concentrations average 2.58 X ICT'j/Ci/ml.
SOIL AND SEDIMENT SAMPLING
Soil samples have been collected for a number of years, and
the program was recently expanded.* Surface soil samples
at distances of 1, 2, and 5 miles from the plant are now
collected twice a year and analyzed for plutonium content.
*Prior to May 1969t soil samples were analyzed for gross
alpha content which includes the contributions from Pu as w
as other alpha emitters and not for plutonium specifically.
-------
RFP-ENV-'
Sediment samples from the four major reservoirs in the
area are collected semiannuaUy. Monthly sediment sahiples
are collected from each of the six holding ponds located
on the plant site. Additional monthly sediment samples
are collected from Walnut and Woman Creeks. Soil sample
results from 1970, incomplete in the last report, are shown
in Table 9. Sediment sample results from the reservoirs,
holding ponds, and creeks, are shown in Table 10. No con-
VEGETATION SAMPLES
Vegetation samples are collected twice a year from 63
locations to a radius of about 20 miles from the plant.
These samples are analyzed specifically for plutonium
content. The results from the latest vegetation sampling
are incomplete at this time.* No concentration standard
exists for plutonium in vegetation.
centration standards exist for plutonium in soil or sediment. 'These results will be
Table 1. Total Long- Lived Alpha Concentrations in Stack Effluents.
Average Concentration
Source January February March
Plutonium
Operations
Bldg. 771 0.005 0 005 0.005
Bldg ITU 0.015 0.010 0.011
Bldg 776 0.004 0.095 0.033
Bldg. 779 0.007 0.002 0 002
Bldg. 559 0.003 0.002 0.002
Bldg. 707 0.003 0.002 0.005
Uranium
Operations
Bldg 444 0 009 0.005 0.002
Bldg. 447 0.071 0.070 0.029
BUg 881 0 004 0 017 0.018
Bldg 883-A 0.010 0.008 0.010
Dldg. R83-B 0.010 0.006 0.003
Bldg. 886 0.003 0.001 0.002
Bldg. 889 0.003 0.002 , 0 002
Bldg. 865 0.002 0.001 0.002
Bldg. 991 -" 0.002 0.002
(flCi/ml X 1012)
April May June
0 015 0.007 0.012
0.01-1 0 060 0 013
0.006 0 018 0.011
0.002 0.002 0.002
0.002 0 003 0 003
0.003 0.005 0.004
0.002 0.002 0 002
0.033 0.040 0.023
0 049 0 005 0.005
0.012 0.041 0034
0.004 0.008 0 005
0.002 0.002 0 002
0.002 0.002 0.002
0.002 0.002 0 002
0.001 0.001 0.002
Average Monthly*
Percent of Standard
for 6-Month
Reporting Period
13.6
34 2
46 4
47
33
6.1
0.12
1 48
0 54
0.64
0 20
0 07
0.07
0.06
0.05
Toldl
Long-Livrd
Alpha Rel<-,v
12. 852
4 r>51
29.069
0 24S
0411
1 091
4 61
18.92
30.11
13.12
4 26
0.06
0 07
0 45
0.02
'Based on the soluble Pu standard of 0 06 X 10~12
note that these existing standards are in terms of averages for a one-year period.
Plenum installed February 1971.
l or the soluble natural uranium standard of 3 X 10U2^Ci/ml. It is important to
-------
54
RFP-ENV-71A
Table 2. Average On-Site Air Sample Concentrations.*
Monthly
Number
Lo( iition Sample1
S-l 124
S-2 124
s-1 124
S-4 123
S-S 1 24
S-(, 124
S-7 124
S-H 124
S-9 124
S-10 1K>
S-SO 124
S-51 124
•Conrenlr.itions includ
**Ha-»ed on the soluble
of Total Long-Lived
i January
0 005]
0.0054
0.0047
0.0041
0.0043
0.0051
O.OOR6
0.0071
0.0054
0.0060
0.0054
February
0.0049
0.0054
0.0043
0.0054
0.0056
0.0049
0.0073
0.0073
0.0049
0.0060
0.0051
0.0058 0.0060
e activity due to natural long-lived
"'Pu standard of 0.06 X 10'12 fiCi
Alpha Concentrations (tfld/ml X 1012)
March
0.0056
0.0058
0.0049
0.0058
0.0047
0.0051
0.0068
0.0083
0.0056
0.0060
0.0056
0.0051
alpha emitters
i/ml, which is
Table 3. Average Off -Site Air Sample Concentrations.*
Number Total Long-Lived Alpha Con
of (/tCi/mlX 1012)
Lo( alion
Moulder (S-15)
Hroomfield (S-17)
Coal Creek
Canyon (S-ll)
Denver (S-2:i)
(, olden (S-20)
Lafayette (S-16)
Marshall (S-13)
Wagner Site (S-18)
Westminster (S-25)
•Concentrations mcl
Samples January
25 0.0056
25 0.0041
25 0.0045
25 0.0011
25 0.0047
25 O.OOM
25 0.0050
25 0.0062
February
0.0050
0 0075
0.0055
0.0035
0.0049
0.0085
0.0045
0.0042
23 0.0060 0.0042
ude activity due to natural long-liv
March
0 0051
0.0069
0.0049
0.0088
0.0073
0.0066
0.0046
0.0050
April
0.0051
0.0054
0.0062
0.0071
0.0051
0.0049
0.0092
0.0323
0.0051
0.0066
0.0092
0.0071
stated in terms
April
0.0062
0.0068
0.0075
0.0080
0.0074
0.0071
0.0046
0.0173
0.0054 0.0090
ed alpha emitters.
May
0.0060
0.0054
0.0062
0.0060
O.OOS4
0.0066
0.0054
0.0094
0.0054
0.0049
0.0056
June
0.0045
0.0045
0.0062
0.0047
0.0058
0.0047
0.0051
0.0094
0.0049
0.0060
0.0073
0.0054 0.0049
of yearly averages.
May
0.0077
0.0056
l
0.0051
0.0060
0.0071
0.0096
0.0054
0.0088
0.0049
June
0.0064
0.0057
0.0064
0.0067
0.004R
0.0077
0.0050
0,0133
o.oisst
Percent of Standard**
Average Maximum
8.7
8.9
9.0
9.2
8.6
R.7
11.8
20.5
8.7
9.9
10.6
9.5
Monthly
Percent of Stan
Average M
9.8
10.4
9.4
10.3
10.1
12.8
8.1
15.2
13.3
10.0
9 7
10.3
11. 8
9.7
11. 0
14.3
53.8
9.3
11.0
IS. 3
11.8
dard**
aximum
12.8
12.5
12,5
14.7
12.2
16.0
9.0
28 8
30.8
**Based on the soluble Pu standard of 0,06 X 10*12 J/Ci/ml, which is ttated in-ierm* of yearly &'
tit in believed that these data are the result of analytical error .
erages.
-------
Table 4. Plutonium Concentrations in High-Volume Air Samples.
RFP-ENV^A
Location
S-26
S-27
S-28
S-29
S-30
S-31
S-32
S-33
S-34
S-35
S-36
S-37
S-ll
s-ia
Number
of
Samples January**
10?
107
107
107
107
106 -
107 -
107
106
108
107
107
14 -
23 0.0008
Average Plutonium Concentration (^iCi/ml>
February
0.00007
0.00006
0.00012
0 00014
0.00009
0.00006
0.00014
0.00019
0.00015
0.00012
0.00009
0.00012
0.0039
0.0022
March
0.00024
0.00020
0.00018
0.00014
0.00015
0.00019
0.00031
0.00031
0.00021
0.00023
0.00033
0.00074
0.0015
0.0012
April
0.00018
0.00012
0.00012
0.00011
0.00010
0.00019
0.00015
0.00018
0.00016
0.00012
0.00018
0.00029
0.0021
0.0031
;1012)
May
0.00027
0.00029
0.00022
0.00026
0.00030
0.00036
0.00030
0.00037
0.00034
0.00030
0.00028
0.00030
0.0016 '
0.0014
June
0.00026
0.00038
0.00036
0.00062
0.00046
0.00037
0.00267
0.00051
0.00070
0.00043
0.00038
0.00042
0.0218t
0.0034
Monthly
Percent ol Standard*
Average Maximum
0.34
0.35
0.33
0.42
0.37
0.39
1.19
0.52
0.52
0.40
0.42
0.62
10.30
3.36
0.45
0.63
0.60
1.03
0.77
0.62
4.45
0.85
1.17
0.72
0.63
1.23
36.33
5.67
* Hascd on the soluble M Pu standard of 0.06 X 1 0 ~l2 ^tCi/ml. which is stated in terms of yearly averages.
•'This air sampling program was started in February 1971.
t It is believed that these data are the result of analytical error.
-------
56
RFP-ENV-71A
Table 5. Plutonium Concentrations in Dustfall Samples.*
Location
Arvada
Hroomfiold
Boulder
Coal Creek Canyon
Denver
Lastlake
Golden
l.alayelte
Marshall
Superior
W't«ner Site
Westminster
Castle Rock
lierthoud
Number of
Samples
10
9
9
8
10
10
10
10
10
9
7
10
S
3
Sam pi B
Days
169
155
141
127
169
169
169
169
169
155
120
169
179
222
A r
{pCi/m /month)
4.25
1.59
15.02
0.98
6.30
4.38
2.46
3.75
13.00
4.80
4.71
4.41
0.75
0.51
•Concentrations include background due to worldwide plutonium fallout. '
**For averaging purposes, sample results that were less than the minimum detectable concentration were assumed to be at the minimum
detectable concentration. Minimum detectable concentration i» <0.50 pCl/m .
-------
ri7
RFP-ENV-71A
Table 6. Radioactivity and Chemical Concentrations in Effluent Waste Water.
Sample
Period
January
February
March
April
May
June
Summary
Number
Volume of
(M liters) Samples
36.01 4
34.85 4
49.18 4
41.21 5
32.36 4
28.15 5
221.76 26
*Gross alpha concentrations refer to
"Although most plutonium processed
standard
Siimple
Period
January
February
March
April
May
June
Guide
Gross Alpha Concentrations*
(flCi/ml X 10')
Avg. Min. Max.
14.33 4.58 36.64
24.74 21.24 27.73
13.15 9.91 19.29
14.75 10.84 19.98
12.54 8.17 19.06
8.33 5.09 10.30
14.64 9.97 22.17
uranium and plutonium activity
at the Rocky Flats plant is ins
Total
Gross Alpha Plutonium Concentrations**
Release (//Ci/ml X 1 0°)
(mCi)
Avg. Mm. Max.
0.516 2.29 0.25 4.01
0.856 2.92 0.28 7.23
0.647 2.86 1.27 4.32
0.608 2.99 1.15 5.23
0.406 2.63 0.81 4.59
0.234 1.60 0.32 2.61
3.267 2.55 0.68 4.67
only and include natural background.
oluble, the more restrictive soluble Pu
Total
Plutonium
Release
(mCi)
0.082
0.101
0.141
0.123
0.085
0.045
0.577
(5 X 10 ^ZCt/ml) is used as the concentration guide.
Number
of
Samples Average
20 7.7
20 7.6
22 7.5
19 7.5
19 8.0
22 8.1
_
f
pH
NO,' PO,J
16.7 10.9
6.2 9.2
9.4 6.3
8.4 4.3
5.5 12.5
3.8 13.3
45.0 -§
Average Concentration (ppm)
F- BOot Total Solids
0.5 5.4 400
0.4 9.9 681
i
0.4 4.5 406
0.4 6.4 392
0.4 5.8 456
0.5 7.3 368
2.4 30.0 500
Cr^
< 0.005
<0.005
<0.005
<0.005
<0.005
<0.005
0.05
TBiological Oxygen Demand. That amount of oxygen required to stabilize a sample or an effluent i.e., allow biological oxidation of organic
matter.
§No Federal Guidelines exist for PO concentrations.
-------
RFP-ENV-71A
Table 7. Community Tap Water Sample Results.
Sample
Locations
Arvada
Boulder
Broomfield
Denver
Golden
Lafayette
Louisville
Thornton
Westminster
Gross Alpha Concentrations*
(/iCi/mlX 10°)
Number of
Samples
12
12
12
12
12
12
12
12
12
*Gross alpha concentrations refer
**The most stringent standard, bas
values represent concentrations of
Avg.
7.64
2.34
2.54
5.73
3.40
1.40
1.24
9.29
Min.
0.56
0.66
0.11
0.53
0.17
0.50
0.25
3.07
2.26 0.43
to uranium and plutonium
ed on soluble Pu is 5
1000 to 10,000 times less
Max.
16.20
6.93
18.58
17.19
8.79
3.23
2.45
17.48
Number of
Samples
2
10
6
11
11
6
3
3
6.49 9
activity only and include natural b<
X 10" ^tCi/ml, in terms of yearly a>
than that allowable by the Standard
Plutonium Concentrations
(/jtCi/mlx 10°)
Avg.t
0.45
<0.29
0.98
<0.44
<0.14
<0.27
0.31
0.18
0.27
ickground.
yerages. These
Min.
0.12
<0.0004
0.09
< 0.0004
< 0.0004
<0.0004
0.04
0.05
0.08
Max."
0.77
0.97
5.03
2.79
0.45
0.77
0.52
0.30
0.60
concentration. (Minimum detectable concentration is 0.0004 X 10 ftCi/ml.)
Table 8. Reservoir Water Sample Results.
Gross Alpha Concentrations* Pljitonmm Concentrations*
Location ViCi/mllX 10°) (/iCi/ml X 10°)
Baseline
Great Western
Ralston
Standley
Walnut Creek
Number of
Samples
12
12
12
11
25
Avg.
3.25
3.12
20.50
i
5.22
11.71
Mm.
—
0.26
1.70
6.01
1.61
2.85
Man.
6.06
6.29
28.79
17.44
30.06
Number of
Samples
11
10
10
9
25
Avg. Mm.
0.33 0 07
0.17 0.04
-t -t
0.30 0 08
2.58 0.67
Max.
1 68
0 64
-t
0 95
8.47
*Gross alpha concentrations refer to uranium and plutonium aclivity only and include natural background.
**The most stringent standard, based on soluble Pu is 5 X 10 f/Ci/ml, in terms of yearly averages. These
values represent concentrations of 1000 to 10,000 times less than that allowable by the Standard.
tBelow detectable limits.
-------
RFP-ENV-71A
Table 9, Plutonium Concentrations in Soil Samples.
Number
of
Location Samples
1 mile 19
16
2 miles 19
16
Smiles 15
13
Table 10. Plutonium Concentrations in Sediment Samples.
Number of
Location Samples
Baseline f 1
C.rrat Western Reservoir 2
RaNton Reservoir 1
Standley Reservoir 2
Walnut Creek 8
Womnn Creek 5
Pond A 6
Total Plutonium (dpm/gram)
AVR. Min. Max.
5.97 <0.06 60.51
11.79 0.09 67.86
3.95 <0.06 26.80
2.10 <0.06 17.73
0.46 <0.06 1.10
0.88 0.11 5.26
Total Plutonium (dpm/gram)
AVR. Min. Max.
1.31
0.70 <0.06 1.33
O.fi? - -
2.04 <0.06 4.01
16.11 4.0 36.0
1 1.31 0.09 2.54
27.0 - -
Pond 1
Pond 2
Pond 3
Pond 4
(composite)
(composite)
(composite)
(composite)
(composite)
216.0
124.00
27.0
32.0
Pond 5
(composite)
2.9
-------
RFP-ENV-71A
-AIR SAMPLER
WEST GATE
EAST GATE
Figure 1. On-Site Air Sampling Locations.
Figure 2. Rocky Flats Plant Environmental Air-Samplmg Off-Site Network.
A -AIR SAMPLER
• -HOLDING PONDS
UPPER CHURCH DITCH
WALNUT CREEK
GREAT WESTERN RES
WOMAN CREEK
SMART CREEK
STANDLEY LAKE
COLO 121
) WESTMINSTER
Note not to scale.
in
-------
PREVIOUSLY PUBLICLY RELEASED
ANNUAL REPORT:
ENVIRONMENTAL SAFEGUARD 71
Protective measures and radioactive levels in the
vicinity of the Rocky Flats Plant, Golden, Colorado
JANUARY - DECEMBER 1971
Health
SI
RFP-ENV-71B
March 10, 1972
Research & Ecology
DOW CHEMICAL U.S.A.
iiiiiiiiiiiiiiiiiiiii
Rocky Flats Division
U.S. ATOMIC ENERGY COMMISSION CONTRACT AT(29-1)-1106
-------
-------
ANNUAL REPORT: ENVIRONMENTAL SAFEGUARD 1971
Radioactive Monitoring and Environmental Surveillance
January Through December 1971
Annual report on radioactive monitoring procedures, and
radioactive levels in the vicinity of the Rocky Flats Plant,
Golden, Colorado
L. M. Steward
M. R. Boss
Prepared by Product and Health Physics Research and Ecology Group,
Rocky Flats Division, Dow Chemical U.S.A.
J. H. Hanes, Rocky Flats Division General Manager
H. E. Bowman, Assistant General Manager for Operations
J. F. Willging, Director; Research and Ecology
J. R. Seed, Director; Product and Health Physics Research
S. E. Hammond, Industrial Hygiene and Bioassay '
DOW CHEMICAL U.S.A.
ROCKY FLATS DIVISION
P. O. BOX 888
GOLDEN, COLORADO 80401
Prepared under Contract AT(29-1)-1106
for the
Albuquerque Operations Office
U. S. Atomic Energy Commission
-------
RFP-ENV-71B
"It is our belief that the nuclear industry can serve the needs of the public without
undue risk to our health or to our environment. But we also believe that we have
the important responsibility of assuring that this continues to be the case in the future."
Joseph A. Liberman
Deputy Assistant Administrator
Radiation Programs
Environmental Protection Agency
July 1971
-------
RFP-ENV-71B
CONTENTS
I. Abstract 1
II. Introductions
Rocky Flats 1
Radiation 2
Radiation Standards 4
III. Standards
Air: Radioactive 6
Non-Radioactive 6
Water: Radioactive 7
Non-Radioactive 7
Other Standards 10
IV. Sample Collection and Analysis Summary
Stack Effluents 10
Air Samplers 11
Dustfall Samples 12
Water Samples 12
Sediment Samples 1.4
Soil Samples 14
Vegetation Samples 15
V. Tabular Data and Maps 15
VI. Summary and Conclusions 32
i
VII. Bibliography 36
VIII. Appendix A 37
-------
RFP-ENV-71B
FOR EWOR D
This report was prepared for submission to the U. S. Atomic Energy Commission by
the Health Physics Research and Ecology Department of the Rocky Flats Division,
Dow Chemical U.S.A. The analyses of all samples described within this report were
performed by the Health Physics Bioassay Laboratory and the Service Laboratories at
Rocky Flats.
All effluents with potential adverse health and safety or environmental effects have
been monitored, evaluated and appropriately controlled.
The AEC has initiated more comprehensive procedures for more complete reporting
of environmental impact information. Due to the new reporting procedures and format,
the data contained within this report are not directly comparable with previous reports
in this series. This is the first report to be prepared under the new AEC guidelines.
-------
RFP-ENV-71B
ANNUAL REPORT: ENVIRONMENTAL SAFEGUARD 1971
Radioactive Monitoring and Environmental Surveillance
January Through December 1971
L. M. Steward
M. R. Boss
I. ABSTRACT
The Rocky Flats Plant maintains an extensive environmental surveillance
program to assess effluent levels and to determine if any accidental release of
environmental contaminants has occurred. Analyses of over 50,000 air,
water, vegetation, soil, sediment and effluent samples for the year indicated
that, in no manner did Rocky Flats contribute significant quantities of
environmental contaminants to the surrounding environs; all radioactive and
nonradioactive effluent levels were below the most stringent and/or restrictive
standards established by regulatory agencies; and, that radioactive levels in
the environs of Rocky Flats have not changed significantly, either on or off
site in the past year.
II. INTRODUCTIONS
Rocky Flats
The Rocky Flats Division of Dow Chemical U.S.A. manages a plutonium
processing facility for the U.S. Atomic Energy Commission. It is located on
a gently sloping plain on the eastern edge of the front range of the Rocky
Mountains and is situated about halfway between Golden and Boulder,
Colorado. To the east'lie the beginnings of the Great Plains of Colorado and a
panorama of Denver, about 16 miles to the southeast. The grassy, gently
rolling hills surrounding the plant provide grazing grounds and winter shelter
for deer, local livestock, and small animals.
Rocky Flats Plantsite Located about
Halfway between Golden and
Boulder, Colorado
Lafayette
pop. 2,612
Broomfield
pop. 7,262
Westminster
pop. 27,008
Golden
pop. 9,817
' Arvada
pop. 46,814
I
Wheatndge
pop. 29,795
Lakewood
-------
RFP-ENV-71B
The climate for which the State of Colorado is so ]ustly famous favors
Rocky Flats with about 300 days of sunshine a year. Rainfall averages |ust
under 14 inches a year and the average temperature is 50 degrees.
The plant handles both plutonium and uranium as well as other potentially
hazardous materials as part of its normal function within the AEC complex.
Rocky Flats maintains a constant surveillance program which continuously
monitors the control of effluents and releases from the plant site and its
operations.
Radiation
There are many naturally occurring, unstable, radioactive nuclides among the
elements with atomic numbeis from 81 (thallium) to 92 (uranium). The
majority of these can be grouped into the uranium series, the actinium series,
and the thorium series. Each decay series begins with a very long-lived
nuclide (parent) as the first member. These parents transform by radioactive
disintegration into mtei mediate members (daughters) until a final, stable,
nonradioactive isotope of lead results. Where found in nature, the uranium
and naturally occurring members of the actmide series are always found
together.
Thi' srrics of disintegrations is known as radioactive decay. The new elements
formed from th" original or "pamnt" atoms are called "daughters." When a
nucleus undergoes this decay process to form a daughter, energy is emitted in
the form ot particulate or electromagnetic radiation. The most common types
of radiation are alpha and beta particles, gamma rays, x-rays, and neutrons.
The alpha particle is the positively charged nucleus of a helium atom
(^ He*2) and is very stable The beta particle is a negatively charged, high-
speed electron that originates in the nucleus. Gamma and x-rays are electro-
magnetic radiations similar to ordinary radio waves and visible light waves
except their frequencies are higher and they are not visible to the human
eye. Neutrons are neutrally charged particles of mass 1. Of these types of
radiation, the high energy gamma ray and the neutron have the greatest range
Rocky Flats Handles Plutonium and
Uranium as Processing Facility for
U.S.AEC
Where 2 "plutonium comes from:
238uranium is bombarded by neutrons
in a reactor to produce ' "plutonium
by the following steps:
Radioactive Decay: "Parent" Elements
Decay to Form New "Daughter" Elements
Alpha, Beta, and Gamma are the Most
Common Types of Radiation.
Alpha and Beta Both Particulate
Radiations. Gamma is Electro-
magnetic like X-Ray.
-------
'VWVvi'V
A/W^
PAPER PLASTIC
LEAD
and penetrating ability, easily
penetratjng several inches of
steel Beta particles, although
IPSS penetrating than gamma,
still have enough penetrating
ability to penetrate the skin of
man. The alpha particle, that of
most concern at Rocky Flats, has the least penetrating power. In fact, the
alpha particle is unable to penetrate an ordinary sheet of paper or the
relatively thick skin of man. Since both plutonium and uranium are primary
alpha emitters, the alpha particle receives the most attention in this report.
•59
RFP-ENV-71B
Alpha Radiation has Least Penetrating
Ability: Will not Normally Penetrate Skin
of Man. This is the primary Radiation of
Concern to Rocky Flats.
Before delineating standards, the actual measurement criteria should be
explained. In relating measured values to the predicted or actual biological
effects, two separate units have arisen.
The first is based on the number of radioactive disintegrations per unit of
time and is thus a quantitative measure of the radioisotope present. Based on
radium-226, the first naturally occurring radioisotope to be isolated in any
quantity, the curie (Ci) became the unit used for expressing quantities of all
isotopes. In 1950 this unit was standardized and is now defined as that
quantity of any radiodctive nuclide undergoing 3.7 X 1010 disintegrations
per second.1 [Disintegrations per unit time are usually abbreviated as dps
(second) or dpm (minute).]
The curie is a very large unit, especially for reporting minute quantities such
as found in environmental radiation measurements. Therefore, subunits of
the curie are usually used. These are the millicune (mCi; 1CT3 Ci), the
microcune (/uCi, 10~6 Ci), the nanocune (nCi; 1CT9 Ci), and the picocurie
(pCi; 10~12 Ci).
1 curie = 37,000,000,000 dps
(le.SgPu219)
1 millicurie - 37,000,000 dps
(0.016 gPu2"19)
1 microcune = 37,000 dps
(0.000016 gPu239)
1 picocurie = 0.037 dps
(0.0000000000163 g Pu"9)
It must be emphasi/ed that these units express only quantities of isotopes
present and not the radiation does these quantities could produce.
The interaction of radiation with matter creates ions by imparting energy to
orbital electrons and stripping them from atoms. The ions thus produced
have either a positive or negative electrical charge. It is this phenomenon
that allows us to detect the presence of radiation, and also determines the
amount of biological damage that a given radiation dose can produce.
Since radiation effects on organisms are due to lomzation, the only quantita-
tive measurement of radiation dose that can be directly related to biological
effects must be stated in terms of this ionization and the amount of energy
absorbed by that organism.
Two Units for Measuring
Radioactivity.
Curie (Based on Disintegrations per Unit
Time) is Measurement of Quantity of
Isotope Present.
Disintegrations per Minute (dpm) and
per Second (dps) are Usual Notations.
Curie Very Large Unit
(37,000,000,000 dps) so
Subunits Usually Used.
Radiation Produces Ions. Amount of
Ionization is Deciding Factor in
Biological Damage so Unit of Dose
Must be in Terms of Ionization.
-------
RFP-ENV-71B
The basic measurement unit, as described by the International Commission on
Radiological Units and Measurements (ICRU), is the roentgen (R). This was
established in 1928, a time when only x-iay or gamma 'radiations were
considered important. It is defined in terms of energy transfer or lonization
to a specific volume of air as the result of an exposure dose of x or gamma
radiation.2 Thus, it is not directly relatable to other types of radiation in
tissues or biological systems.
Basic Unit is Roentgen, Based on the
lonization Produced by X-Ray and
Gamma-Radiation Only; Not Directly
Relatable to Other xmts of Radiation.
This shortcoming in the definition of the roentgen has led to the introduction
of another unit, the roentqen equivalent (for) man, or the rem. This unit is
that quantity of ionizing radiation which, when absorbed by man, produces
an effect or biological response equivalent to the absorption of one roentgen
of x or ()c\mma radiation.3 Since the biological effects due to radiation are
known to vary, a quality factor ranging from one to twenty is included in
the rem * A primary subunit of the rem, the millirem(mrem) or 0.001 rem,
is very often used in describing biological radiation exposures.
Modified Unit is Roentgen Equivalent,
Man (REM), which Includes Modifica-
tion Factor to Account for Differences
in Types of Radiation.*
Radiation Standards
In 1928, an international group was convened to establish standards for
ionizing radiation and formed the International Commission on Radiological
Protection (ICRP). The committee charged with establishing those standards
was composed of scientists from Great Britain, the United States, Germany,
and Sweden. Later, they were joined by members from France and Italy.
International Commission on Radio-
logical Protection (ICRP) Formed in 1928.
To establish unanimity among representatives to the ICRP, it was decided that
each membpr nation should have one official representative. Thus, in 1929,
what became the National Committee on Radiation Protection and Measure-
ments was established under the auspices of the National Bureau of
Standards.''
U. S. Representative to ICRP is
National Council on Radiation Pro-
tection and Measurements (NCRP).
In 1964, this national committee was granted an independent status and
charter by Congress and changed its name slightly to become the National
Council on Radiation Protection and Measurements (NCRP). The NCRP,
in coniunction with its international counterpart, the ICRP, has, since
1929. provided the basic standards and guidance in the field of radiation
protection.5
In 1959, the Federal Radiation Council (FRC) was formed to provide a
federal policy on human exposures to ionizing radiation. The FRC, whose
responsibilities were absorbed in 1970 by the new Environmental Pro-
ii'ction Agency (EPA), ddoptcd those guidelines recommended by both the
NCRP and ICRP. These guidelines were based on five principles in
determining permissible levels'6
1. It is appropriate to set different standards for different
sources of emissions and exposures.
2. Exposure to radiation should always be as low as possible. •
NCRP, an Independent, Objective
Organization has Provided Basic Guidanc
in Radiation Protection Since 1929.
Federal Radiation Council Functions
Absorbed by Environmental Protection
Agency in 1970.
""Whereas all radiations produce the same types of biological effects, the magnitude of response per unit of absorbed dose is not (he same
The inverse ratio of the absorbed dose from one radiation type to that of a reference radiation required to produce the same degree of a
stipulated effect is referred to as Relative Biological Effectiveness (RBE) There is actually no one RBE for a given type of radiation, the
value depends on the total dose, dose rate, tissue, cell, and/or the biological effect being studied."
-------
RFP-ENV-71B
3. No exposure should be allowed without expectation
of benefit.
4. That all radiation is assumed to be harmful or potentially so.
5. And, that the biological risk associated with higher levels
of exposure is proportional to those risks at lower levels.
(Since these lower levels refer to exposures due to or
comparable with natural background radiation, this
assumption of proportionality provides a most
conservative guideline.)6
Both FRC and EPA Followed Five
Basic Premises in Establishment of
Radiation Protection Guidelines.
The U.S. Atomic Energy Commission has incorporated the guidelines and
recommendations of the NCRP, ICRP, and the FRC into its own operational
procedures for AEC installations and those of contractors and licensees.7'8
The entire history of the derivation of radiation standards has been one of
objective, conservative evaluation of the best data available. Guidelines have
been internationally derived, accepted, and endorsed.5
The permissible dose of occupationally exposed individuals, 5 rem per year
to the whole body, is defined by the National Council on Radiation
Protection and Measurements as:4
". . . that dose, accumulated over a long period of
time or from a single exposure, which in the light
of present knowledge, carries a negligible probability
of severe somatic or genetic injuries. . ."
Based on all present technical knowledge, authorities have concluded that
this level can be absorbed per year by a man throughout his working lifetime4
without his sustaining any measurable damage.*
In contrast to this controlled group (i.e., the occupationally exposed),
individual members of the general public include persons of all ages and
degrees of health. The established standards reflect this prudent, conserva-
tive attitude toward exposures to the general public.
For an individual in the general population the whole body radiation exposure
guide is given as 0.5 rem per year, one tenth that of the occupational
expsoure level When a group of individuals is at risk, the whole body
radiation exposure for the average of a suitable sample of the group must be
less than 0.17 rem.4
It must be noted then that the established standards, accepted by international
authorities, are in terms of portions of the body irradiated and the period of
time over which that dose is delivered.
i
Important too is the relatively low penetration power of the alpha particle.
Alpha particles must be taken into the body to do any radiation damage to
man; i.e., in the foods we eat (ingestion), the air we breathe (inhalation),
or through a wound or break in the skin.
Entire History of Present Standards
is One of Objective, Conservative
Evaluation.
Occupational Dose is 5 REM Per Year
Limit to Whole Body.*
Since General Population is Uncontrolled
Group (i.e. contains all ages, health, etc.)
General Standards Far More Conservative
Standards are in Terms of Group, Portio
of Body Irradiated, and Period of Time
Over Which Dose Delivered.
Alpha Particles Must Be Taken Into
Body to Do Any Radiation Damage
to Man.
For perspective, it should be emphasized that the NCRP believes that its recommendations provide ". . .a system that offers far lower
occupational risk than is found in many occupations normally considered not to be extra hazardous."
-------
RFP-ENV-71B
III. STANDARDS
Air
Radioactive
The short range alpha particle will be completely absorbed by a small amount
of tissue when taken into the body. This complete absorption represents a
greater dose or exposure than that received from a gamma ray having the
same energy. The gamma ray, with its higher penetration power, can pass
completely through the body and thus transfer only a portion of its energy to
the body tissue.
Therefore, when alpha particles are inhaled, they can stay in one portion of
the lung and irradiate one small area of tissue quite heavily.* To prevent this
effect, the most restrictive standards are those for plutonium in air.
The current established standard for soluble plutonium in air is 0.06 x 10~12
fjCi/ml of air in terms of exposure to an individual in the population and
0.02 x 10~12 fjCi/ml to a suitable sample of the population7'8'9 in terms of
yearly averages.
STANDARDS FOR SOLUBLE Pu239 IN AIR.
Radiation Workers 2.0 x 10"12 /jCi/ml
General Populace- Individual 0 06 X 10~12 nC\/m\
Total Population (suitable sample) 0.02 X 10~12 f/Ci/ml
Source: NBS Handbook, 69, USAEC Manual, Chapter 0524
Most Restrictive Standards are for
Alpha Emitters in Air.
For uranium (soluble-238), the applicable standards are 3 x 10"'2
for an individual and 1 x' 10~12 /jCi/ml for a suitable sample of the total
population.7'8'9 These standards are based on the soluble materials, are
stated in terms of yearly averages above the levels of naturally occurring
alpha activity and apply at the plant boundary, the point of public access.'
4,9
STANDARD FOR URANIUM IN AIR:
INDIVIDUAL: 3 x 1(T12
TOTAL POP.: 1 x NT12
Total population standard for soluble plutomum-239 is
002 X 10~'2jjCi/ml. This is equivalent to about 3.3 X 1CT19
(0.00000000000000000033) gram of plutonium, or
1.2 X 10~2n (0.000000000000000000012) ounce of plutonium
per milliliter of air. Based on the specific activity of
plutonium-239, this would be just one particle about 3/1000
micron (0.00000013 inch) in diameter/ml of air.
Non-Radioactive
t
The standard most applicable to nonradioactive operations at Rocky Flats
is that for beryllium. In terms of monthly averages, this standard is'
1 x 10~5 milligrams per cubic meter (mg/M3) of effluent air. This standard
was established by action of the American Conference of Governmental
Hygienists and modified by an Advisory Committee to the AEC.10
Beryllium Standard in Air = 0.01 jjgrams
Per Cubic Meter (1 x NT5 mg/M3).
"it must also be noted that since fewer cells are involved, this possibility might, in effect, do even less damage than originally presumed.
-------
The EPA used these guidelines in their proposed beryllium standards as
published in the December 7, 1971 Federal Register. ,The proposed
standard states that total beryllium releases shall not result in outplant
concentrations that exceed 10 grams in any 24-hour day, or concentrations
of greater than 0.01 micrograms/cubic meter (1 x 10~5 mg/M3) as
averaged over 30 days.11
The Rocky Flats self-imposed internal goal for beryllium in air is one-half
the official standard or 5 x 10~6 mg/M3.
RFP-ENV-71B
EPA 1971 Standard is Same as AEC
Beryllium Standard for its Contractors
and Licensees.
Water
Radioactive
The most restrictive recommended guideline for plutonium-239 (soluble) in
water is 1.67 x 10"* fiC\/m\ to a suitable sample of a population on a yearly
average. For an individual within that population, that guideline is given as
5 x 10~6 pCi/ml on a yearly average.7'8'9
The most restrictive standard for uranium, that for the uranium-235 isotope,
is 3 x 1 (T5 /nCi/ml in terms of an individual in the population, or
1 x 10~5 nC\/m\ for a suitable sample of the total population on a yearly
basis."
7,8,9
In addition, gross alpha and gross beta guidelines to limit total radioactive
nuclide content have also been established by the NCRP,4 the AEC7'8
the Colorado Department of Health12 and U.S. Public Health Service.13
Those standards adopted by the latter two agencies are based primarily on
the recommendations of the Federal Radiation Council and thus the
NCRP. Gross alpha standards for Rocky Flats effluents would be the same
as the given standard for plutonium since it is one of the constituents of the
mixture and has the most restrictive limit. Where the identity and con-
centration of both uranium and plutonium are known, a somewhat more
complex derived standard is applicable.7'8'9
Established standards for soluble americium-241 in water are 4 x 10~6
/jCi/ml for individual and 1.33 x 10~6 /^Ci/ml for a suitable sample of a
population in terms of yearly averages.7'8'9
Non-Radioactive
STANDARDS FOR SOLUBLE Pu335
IN WATER: Radiation Workers
100 x 10~6 ^Ci/ml. General Populace:
Individual 5 x 10~VCi/ml. Total
Population (suitable sample)
1.67x10~6MCi/ml.
Most Restrictive Standard for Uranium in
Water (Soluble U235 Is: 3 x 10"s
for Individ., 1 x 10~5AtCi/ml for Total
Population (suitable sample).
U.S. Public Health Service and Colorado
Department of Health Guidelines are
Based on NCRP Recommendations.
The U.S. Public Health Service Drinking Water Standards (1962) are the
primary guidelines followed at Rocky Flats. The Water Pollution Control
Commission of the Colorado Department of Health is, however, the agency to
which Rocky Flats is directly responsible. That agency is responsible for the
administration of the USPHS guidelines and, in some cases, has established
standards of its own. In addition, the Water Pollution Control Commission
has compiled classifications for the" major water sources of Colorado
according to uses. Although Walnut Creek has not been classified, the.most
restrictive classifications (A, BI , C, and DI ) are those adhered to. The basic
Colorado Standards were revised effective September 1, 1971.'2 These
new standards for Class A, B], C, and DI water sources are summarized below.
Also summarized are those chemical guidelines delineated by the U. S. Public
Health Service in the Drinking Water Standards of 1962.13
For Chemical Contaminants in
Effluent Waste Waters, Rocky Flats
Responsible to Colorado Department
of Health.
Rocky Flats Effluents Discharged into
Walnut Creek.
-------
74
RFP-ENV-71B
WATER QUALITY STANDARDS
Water Pollution Control Commission Colorado Department of Health
I. Basic (Non-Radioactive) Standards Applicable to All Waters of the State
A. All waters capable of treatment or control prior to discharge into any
waters of the state shall receive secondary treatment with disinfection
or its industrial waste equivalent.
Waters shall be free from substances attributable to municipal, domestic,
or industrial wastes that:
B. Will either settle to form unsightly, putrescent or odorous bottom
deposits or will interfere with the classified use of the water;
C. Create unsightly floating debris such as oil, grease, or scum;
D. Will produce objectionable odor, color, taste, or turbidity, or
objectionable aquatic life;
E. May, in sufficient levels, concentrations, or combinations
prove deleterious to human or animal life.
II. Additional Water Quality Standards (most restrictive from Class A, B,, C, and D,)
A. General (Colorado Department of Health)
Parameter
Fecal Coliform
Bacteria
Dissolved Oxyqen
pH
Turbidity
Total
Dissolved
Solids
Toxic Materials
(Biocides,
Pesticides, etc.)
i
Temperature (°F)
Limits
<1000/ml
6 mg/l
6.5-8.5
Not to impair natural and
developed fisheries
Less than 500
mg/l (annual
volume-weighted average)
Free From
70
Sodium Adsorption Review of Commission
Ratio
Classification
A, BI
BI
B,
1
A, B,
All
B,
C, D,
Taste & Odor
Free From
A, B,
-------
RFP-ENV-71B
B. Chemical
Limits (mg/l)
Parameters
Alkyl Benzene
Sulfonate
Arsenic
Barium
Cadmium
Chloride
Cr6+
Copper
Carbon
Chloroform
Extract
Cyanide
Fluoride
Iron
Lead
Manganese
Nitrate
Phenols
Selenium
Sulfates
Silver
Zinc
CDH
A, B,
-
0.05
1.00
0.01
-
0.05
0.05
-
0.20
-
-
0.05
-
-
-
0.01
-
0.05
Suggested
Maximum
(USPHS)
0.500
0.010
-
-
250.
-
1.00
0.200
0.010
1.200
0.300
-
0.050
45.0
0.001
-
250.
-
5.00
Grounds for
Rejection
(USPHS-CDH)
-
0.05
1.00
0.01
-
0.05
-
-
0.20
2.40
-
0.05
-
-
-
0.01
-
0.05
_
A Colorado guideline for the Biochemical Oxygen Demand (BOD) — the
amount of oxygen needed to allow for natural, biological oxidation of
organic matter - has been established, primarily as a measurement of
sewage treatment effectiveness. The BOD guideline for Rocky Flats is
30 mg/l.
No standards have been established for phosphate levels.
Measure of Success of Secondary
Waste Treatment is BOD.
-------
RFP-ENV-71B
Other Standards
Although no directly applicable standards currently exist for plutonium
and/or uranium levels or non-radioactive materials in soil, sediments,
vegetation, or dustfall samples, the guide at Rocky Flats has always been to
maintain these levels as low as is practicable in accordance with the guide-
lines of the National Council on Radiation Protection and Measurement.4
No Applicable Standards for Soil,
Sediments, Vegetation, or Dustfall, so
Guideline is that of the NCRP:
Maintain Levels as Low as Practicable.
IV. Sample Collection and Analysis Summary
Stack Effluents
Exhaust ducts from buildings involved with
and/or beryllium are continuously sampled.
FILTER PAPER
FLOW
RATE
MANOMETER
ISOKINETIC DUCT
SAMPLER
processing of plutonium, uranium,
An iso-kmetic technique is used
whereby the air moving into the
sample device is at the same
velocity as the air inside the duct.
This technique allows improved
trapping of particulate matter by
eliminating turbulence at the
mouth of the sample tube.
Samples are taken continuously
and analyzed for total long-lived
alpha activity (including natural,
long-lived alpha emitting
materials) and/or beryllium
where applicable. Total activity
released is then calculated from
total effluent volumes.
Exhaust Ducts of Process Buildings
Continously Sampled Using Isokinetic
Device for Better Particulate Trapping.
Samples Analyzed for Gross Alpha and/or
Beryllium Where Applicable.
Since most standards apply to concentrations measured at the point of
public access (plant boundaries),4' 9 measurements taken at the stack
discount any dilution effect and thus provide an additional safety factor.
The guides for effluents are for contributions (above naturally occurring
activity) after dilution by the atmosphere in terms of timed averages.
The values obtained at Rocky Flats are taken at the stack and include natural
activity before any atmospheric dilution. These results, summarized in
Tables IA and IB indicate a maximum (one-month average) long-lived alpha
concentration of 0.095 x 10~12 fjCi/ml for all plutonium operations.
The yearly average (the pertinent value in terms of the guidelines) was
0.009 x 10~12 nCi/ml, about 15% of the standard.
The maximum (one-month average) total emission from all uranium
operations (Table 1C and ID) was 0.05 x 10~12 jjCi/ml. The yearly average
was 0.008 x 10~12 /nCi/ml, which is about 0.3% of the applicable
(population) standard.
Maximum (one-month average) beryllium emission was 1.5 x 10~s mg/cubic
meter (before atmospheric dilution). The 12-month average stack release for
all beryllium operations was 1.3 x 10~9 milligrams per cubic meter or about
13% of the standard. Beryllium results are tabulated in Tables IIA and MB.
Standards Apply at Plant Boundaries ...
Samples Taken and Results Reported at
the Stack Before Appropriate
Atmospheric Dilution.
i
Results Summarized in Tables
lAandlB.
Maximum Concentration for All Plu-
tonium Releases Occurred During
Filter Change.
10
-------
77
RFP-ENV-71B
Air Samplers
To provide further detection and measurement of any'accidental release
of any contaminated effluents, Rocky Flats maintains an extensive network
of continuously operating air sampling devices to monitor contamination
levels in the surrounding atmosphere.
ELECTRIC MOTOR
FILTER
PAPER
TYPICAL
AIR-SAMPLER
Continuous samples are obtained
from 12-on-site air sampling
stations (Map 1) which sample
about 82 cubic meters of air per
day (the equivalent of 2 cubic feet
per minute). These samples are
collected and analyzed daily for
total long-lived alpha concentrations
(which would include plutonium,
uranium, and other long-lived alpha
emitters) and specifically for
beryllium (see Map 1).
Twelve high-volume air samplers are located at a radius of about 2 miles
from the plant perimeter (Map 2). These samples are collected on a 4-inch
filter paper, which is changed daily, composited and analyzed specifically for
plutonium. The 437 composite samples for 1971 represent volumes of over
2,000,000 cubic meters (about 70,000,000 cubic feet) of air actually
filtered in 1971.
Extensive Network of Air Samplers
Maintained to Detect Levels and
Accidental Releases
12 (Continuous Operation) Air
Samplers on Plantsite; Sample About
2 Cubic Feet Per Minute, Samples
Analyzed for Long-Lived Alpha.
12 High Volume Samplers Offsite,
Surrounding Plant at About 2 Mile Radius.
Samples Analyzed for Plutonium.
High-volume samples are also taken weekly from Wagner Site (S-18, Map 2)
and from Coal Creek Canyon (S-11, Map 2), about 2.5 miles southeast and
3 miles west southwest of the plant, respectively. For 1971, the 77 samples
taken represent volumes of about 17,000 cubic meters of air (nearly
600,000 cubic feet). These were analyzed specifically lor plutonium.
Results for the year indicated a maximum-of 0.06 x 10~12 /jCi/ml. High-
volume grab samples were also taken to the east of an asphalt pad covering
some contaminated soil (former drum storage area in the southwest corner of
the plant-site proper) The 180 samples taken in 1971 represent over
40,000 cubic meters of air actually filtered and were analyzed for total
plutonium content. The results varied from a single sample maximum of
0.049 x 10~12 (jCi/ml to a yearly average of 0.0030 x 10~12 //Ci/ml.
Nine low-volume air samplers, programmed to sample for 10 minutes of each
hour, are located in Boulder, Broomfield, Denver, Coal Creek Canyon,
Golden, Lafayette, Westminster, and Marshall (Map 3). These samples are
collected weekly and analyzed for total long-lived alpha activity. The low-
volume samplers represent about 44,000 cubic meters of air during 1971.
This complex of air samplers produces nearly 10,000 samples per year. These
are analyzed to make certain that effluent levels as well as any re-distrtoution
effects are kept well below guideline concentrations. Summaries of these
results for 1971 are presented in Tables III, IV, and V. On-site air samples
varied from a maximum average long-lived alpha concentration (one-month
average) of 0.0128 X 10~12 nC\/m\ with a 12-month average of
0.0049 X 10~12 ^Ci/rnl, about 24.5% of the standard.
Special High Volume Sampk -. Also
Taken Onsite and at Two Offsite
Locations on Regular Basis, Analyzed
for Plutonium.
Low-Volume, Programmed Samplers
Located in Surrounding Communities.
Weekly-Samples Analyzed for Total
Long-Lived Alpha (Nearly 10,000
Samples Per Year).
11
-------
18
RFP-ENV-71B
Low-volume, off-site air sample results were also quite low. The programmed
samplers indicated a maximum long-lived alpha concentration (one-month
(average) of 0.01 X 10~12 juCi/ml with a yearly average of 0.0044 X 10~12
/jCi/ml, about 66% of the guidelines. The high-volume, off-site samplers,
much more indicative of chronic exposure levels, revealed much lower con-
centrations. The maximum (one-month plutonium average) was 0.004 x 10~12
jjCi/ml whereas the average for the year was 0.0003 x 10~12 fzCi/ml, about
1.3% of the guideline.
Data from the air-sampling network indicate that the average contaminant
concentrations in air effluents from Rocky Flats were below the established
standards.
Average Concentrations Below
Established Guidelines.
Beryllium sample results were also far below guideline concentrations
(Table VI). Nearly 12,000 analyses of these air samples indicate that in no
case did off-site beryllium concentrations exceed 1.87 x 10~5 milligrams per
cutib meter* and that the yearly average was 2.8 x 10"' mg/M3, roughly
30% of the applicable standard. On-site results were considerably lower,
ranging from a maximum of 2.3 x 10~6 mg/M3 to a yearly average of
1.2 x 10~6 mg/M3 indicating that cross contamination occurred in an
analysis of the off-site samples.
Dust-fall Samples
In addition to the air samples obtained, specially designed trays atop all the
off-site air stations collect dustfall samples for specific plutonium analysis.
In addition, more remote samples are collected from locations near Berthoud
a vl from Castle Rock. Table VII tabulates these results for the year. All
sarr pies are collected on a bi-monthly basis, and represent fallout from
atmospheric weapons testing, and, of course, any contribution from Rocky
Flats. Castlfi Rock and Berthoud samples are collected to provide an indica-
tion of plutonium in dus'tfall samples from background. The values obtained
in this extensive sampling program are on the same order of magnitude as
reported for world-wide fallout measurements.14 These levels represent no
health or safety hazard. There is possibly some insignificant but nonetheless
real contribution from Rocky Flats. Studies are now underway to determine
what (if any) contribution is directly attributable to Rocky Flats.
Water Samples
Rocky Flats is drained by three streams; North and South Walnut Creeks to
the north of the plant-site, and Woman Creek to the south. For reference,
North Walnut Creek is classified as the plant's "A" drainage. South Walnut
Creek as the "8" drainage, and Woman Creek as the "C" drainage.
Sanitary and process waste waters are released after treatment to South Walnut
Creek through a series of four holding ponds (Ponds B-1, B-2, B-3, B-4).
Effluents released through the sewage plant meet all Water Quality Standards
as established by the Colorado Department of Health12 or the U.S. Public
Health Service Drinking Water Standards Act (1962).l3 The overflow from
the pond system (Ponds B-1 through B-4) flows into Great Western Reservoir.
Beryllium Results Also Below
Guidelines.
Dustfall Collection Trays Mounted Atop
all Off site Air Samplers.
Dustfall Results Same Order of Magnitude.
as Worldwide Fallout, But Possibly Some
Contribution From Rocky Flats. This
Under Intensive Study.
Levels Represent No Health or Safety
Hazard.
Three Drainage Streams: North Walnut
Creek (A), South Walnut Creek (B),
Woman Creek (C). (Discharges Made
Only to South Walnut Creek (B)
Through Four Holding Ponds.)
'Although these data are believed to be the result of analytical error due to their high deviation from the average, it is felt that it mould be
far better to err on the conservative side and they are thus presented as maximum*.
12
-------
RFP-ENV-71B
Continuous flow into this reservoir is comprised mainly of liquid wastes from
Rocky Flats and makes up a small portion of the drirtking water for the
community of Broomfield.
Holding Ponds Also Located on (A) and
(C) Drainages.
Holding ponds are also located on North Walnut Creek (Pond A) and on
Woman Creek (Pond C), but no effluents are discharged directly into these
holding ponds.
Daily water samples are collected from Pond B-4, and three times weekly from
the Ponds A and C. These samples are composited into a weekly sample and
analysed for their gross alpha (uranium and plutonium) content as well as
specifically for plutonium and for amencium.
Water Samples Collected Daily From B-4,
Three Times Each Week From (A) and
(C).
Tap water samples from the surrounding communities (Arvada, Boulder,
Broomfield, Denver, Golden, Lafayette, Lousiville, Thornton, and
Westminster) and water samples from four reservoirs in the area are collected
every 2 weeks, and analyzed specifically for gross alpha and plutonium.
Standley and Great Western Reservoir water samples are also analyzed for
americium.
Tap Water Samples Taken From
Surrounding Communities Every 2
Weeks, Along with Four Reservoirs
in Area.
Weekly grab samples are taken from Walnut Creek below the confluence of
the North and South branches and analyzed for gross alpha and specifically
for plutonium and americium content. As a further safeguard, nearly all
waters in the immediate vicinity are surveyed semi-annually and analyzed for
gross alpha (uranium and plutonium) and for plutonium content. There are
34 such bodies of waters surveyed, 18 within 5 miles of the plant site
and 16 at distances greater than 5 miles.
Most Waters in Area Sampled for
Gross Alpha and Plutonium.
The most restrictive standard, that for soluble plutonium-239, is 1.67 x 10 6
/jCi/ml in terms of yearly averages to a suitable sample of a population. Gross
alpha concentrations in samples from B-4 pond had a maximum of
36.6 x 1CT9 AiCi/ml, and a yearly average of 11.69x 10~9 /iCi/ml. These
gross alpha concentrations are contributions from both plutonium and
uranium. All other naturally occurring long-lived alpha emitters are removed
from the samples during the analytical procedure.
Total maximum plutonium concentration in Pond B-4 was 7.23 x 10~9
^Ci/ml with a yearly average of 2.06 x 10~9 j/Ci/ml. Americium-241
maximum was 3.07 x 10~9 j/Ci/ml with a yearly average of 1 x 10~9
AiCi/ml.
Average Gross Alpha, Americium
and Plutonium Concentrations
Below Guidelines.
Grab samples from Pond A showed a maximum gross alpha concentration
of 17.65 x 10~9 /jCi/ml, with a yearly average of 7.28 x 10~9 /^Ci/ml.
Pond C showed similar low concentrations with a yearly maximum (gross
alpha) of 23.64 x 10~9 fjCi/ml an'd a yearly average of 6.14 x 10~9 /LiCi/ml.
Those grab samples taken at the confluence of North and South Walnut
Creeks showed a maximum gross alpha of 49.34 x 10~9 /^Ci/ml. Maximum
plutonium concentration found was 8.47 x 10~9 /^Ci/ml, and maximum
americium was about one-half that amount. Average gross alpha was 11.55,
average plutonium 2.56 and average americium 0.80, all x 10~9 fid/ml.
13
-------
RFP-ENV-71B
Tap water results averaged 3.33 x 10 9 /LtCi/ml with a maximum of
18.58 x 1CT9 jLiCi/ml gross alpha activity. Gross alpha concentrations in the
reservoirs averaged 6.38 x 10~9 /jCi/ml with a maximum1 of 28.8 x 10"'
in Broomfield.
Average plutonium concentrations, summarized in Tables VI HA and B,
show that all water samples, from tap water, reservoirs, and holding ponds
were 1000 to 10,000 times less than the most restrictive standard for soluble
plutonium.
In addition to the radionuclide analyses performed on these effluents, the
daily chemical analyses of the B holding ponds, sanitary and process waste
effluents, and weekly grab samples taken from Ponds A and C, show them to
be within both State and Federal specifications (Table VIIID and VINE.)
Tap Water From Surrounding Commun-
ities and Reservoir Samples Below Gross
Alpha (U + Pu) Guidelines.
Average Plutonium Content of Tap Water
and Reservoir Samples 1000 to 10,000
Times Less Than Guidelines.
Chemical Analyses Also Below
USPHS and Colorado Guidelines.
Sediment Samples
Sediment samples from the four major reservoirs are collected semi-annually
and more frequent sediment samples are taken from each of the six holding
ponds. Additional samples are also taken from Walnut and Woman Creeks.
These samples are taken to a depth of 4 centimeters. No specific standard
now exists for plutonium in sediment samples. The results, tabulated in
Table IX indicate a maximum of 0.641 x 10~3 /^Ci/gram (dry) within the
controlled area. The yearly average within the controlled area was 0.03 x 10~6
^iCi/gram (dry). The maximum concentration found outside the controlled
access area of the plant site was 7 x 10~6 pCi/gram with a yearly average of
7 x 10~9 fjCi/gram.
No analyses are performed for nonradioactive materials in sediment samples.
No Standards for Sediment Samples.
Soil Samples
The Rocky Flats Health Physics Department has maintained an extensive
soil sampling program on a routine basis since mid-1969. Previous to that
time, samples were taken on a random basis and analyzed for gross alpha
content. Although this gross alpha analysis would include plutonium and
uranium as well as naturally occurring radionuclides, no specific plutonium
analyses were routinely performed on these soil samples prior to that time.
The current program draws samples from a rough grid at 1, 2, and 5-mile
distances from the center of the plant. About 75 locations,
predominantly east and south of the plant site (corresponding to prevailing
wind directions) but covering all areas between the perimeter and cattle
fences, are sampled twice each year. In addition, locations along public right-
of-way are also sampled, and samples are taken from Denver, Arvada, West-
minster, between Boulder and Fort Collins, between Leyden and Golden,
along 104th Avenue and in Coal Creek Canyon. All samples are to a depth of
1 centimeter. In all, 159 soil samples were collected in 1971 and analyzed
specifically for plutonium.
Routine Soil Sampling Since Mid-1969.
Current Program Uses 1, 2. and 5-Mile
Grids. 159 Samples in 1971 Analyzed
Specifically for Plutonium.
No specific standard has been set for plutonium in soils. The levels obtained
in this sampling program are summarized in Table X.
No Standard for Plutonium in Soils.
14
-------
All evidence gathered to date by the Rocky Flats Health Physics Department
and other official agencies indicate that the plant has made some contribution
to plutonium soil concentrations in the immediate vicinity of the site. There
is, however, no evidence to indicate that there has been any measurable or
significant contribution to the Greater Denver Metro areas surrounding the
plant. Nor is there any evidence that the levels found closer to the plant
represent any health hazard.
81
RFP-ENV-71B
Plant Made Some Contribution to Pu
Soil Concentrations in Immediate
Vicinity. No Evidence of Any Measurable
or Significant Contribution to Greater
Denver Metro Areas, nor Any Evidence
That Levels Found Represent Health
or Safety Hazard.
Vegetation Samples
Vegetation samples are collected from 75 locations within a radius of 20
miles from the plant site. These are taken from public right-of-way twice each
year, and are confined to those plants normally consumed by grazing domestic
animals. The various samples are analyzed specifically for plutonium.
Results for 1971 (Table XI) show that plutonium levels were a maximum of
2.54 x 10~6 ^Ci/gram (dry). One notable aspect of this sampling program is
that the plant is analyzed without any prior washing. Thus, the plant be-
comes a form of dustfall collector as well as a measurement of the amount of
plutonium physically incorporated into the plant through normal growth
activities. Although no specific standard has been established for plutonium
in or on plants, these levels are considered by most experts to be insignificant,
especially in light of empirically derived dilution factors.15
Vegetation Samples Collected Twice
Yearly from 75 Locations, Analyzed
Specifically for Plutonium.
No Standard for Plutonium In
Vegetation. Levels Found Are Con-
sidered Safe.
No specific routine analyses are performed at Rocky Flats on food or bio-
logical samples. Specific studies are now under way on vegetation and
biological samples by Rocky Flats and by C.S.U.
Rocky Flats has contracted with the Radiobiology Department of Colorado
State University to make ecological studies of the flora and fauna in the
immediate environs of the plant. This will be a continuing project.
C.S.U. Ecology Studiet of Plant Site,
A Continuing Project.
V. Tabular Data, 1971
Map 1. On-site high-volume air sampling stations and weather summary.
Map 2. Off-site high-volume air sampling stations.
Map 3. Programmed environmental sampling network.
Map 4. Rocky Flats effluent water flow.
Table I. Radioactive stack effluent releases.
A. Plutonium concentrations.
B. Yearly summation, pfutonium concentrations.
C. Uranium concentrations.
D. Yearly summation, uranium concentrations.
Table II. Non-radioactive stack effluent releases.
A. Beryllium concentrations.
B. Yearly summation, beryllium concentrations.
15
-------
RFP-ENV-71B
Table 111. Average monthly air sample concentrations, on-site, radioactive.
A. Long-lived alpha concentrations. '..
Yearly summation, long-lived alpha concentrations.
B.
Table IV.
A.
B.
Table V.
A.
B.
Average monthly air sample concentrations, off-site, radioactive.
Low-volume, programmed samplers.
1. Long-lived alpha concentrations.
2. Yearly summation, long-lived alpha concentrations.
High-volume off-site samplers.
1. Plutonium concentrations.
2. Yearly summation, off-site plutonium concentrations.
Special high-volume air samples, radioactive.
On-site grab samples and summation.
Off-site grab samples and summation.
Table VI. Average monthly beryllium concentrations in air samples, on- and off-site.
Table VII. Dustfall sample summary.
Table VIII. Water surveys.
A. Radioactivity in holding ponds and effluent waste waters.
1. Pond B-4.
2. Grab samples, Ponds A and C.
3. Walnut Creek at Indiana (confluence).
B. Radioactivity in reservoir and tap water samples.
1. Reservoir water samples.
2. Comrriunity tap water samples.
C. Semi-annual water collection.
D. Chemical concentrations in holding ponds and effluent waste waters.
1. Pond B-4.
2. Pond B-4 summary.
3. Pond B-4 elemental analyses.
E. Chemical concentrations in holding ponds and effluent waste waters.
1. Grab samples. Ponds A and C.
2. Yearly summary. Pond A.
3. Yearly summary, Pond C.
Table IX. Sediment samples.
Table X. Semi-annual surface soil analyses - off-site contours.
Table XI. Vegetation samples. ,.
Analytical Note: For all samples below detection limits, a value was assigned. This value is a fraction of the detection limit;
i.e., the number of samples above the detection limit divided by the total number of samples that were
analyzed.
16
-------
RFP-ENV-71B
p o
/-7?E
Weather Summary, 1971
For 1971, weather records show that the average temperature was 50.2 degrees
Fahrenheit, and ranged from minus 2 to 102 degrees. The average relative humidity
was 48.1%. Monthly precipitation ranged from 0.15 inch in November to a
maximum 3.78 inches in April. The average precipitation for the year was about
1.2 inches per month, with a total for the year of 14.3 inches. Although winds
at Rocky Flats averaged only 8.7 miles per hour, peak wind velocities exceeded
40 miles per hour in all 12 months, ranging from 43 miles per hour in May 1971,
to 95 in January. Average peak velocity for all 12 months was 31 miles per hour.
The prevailing winds below from the northwest 20% of the time and from the
west about 18% of the time. (A directional wind rose is included with Map 1.)
AIR SAMPLER
1971 DIRECTIONAL
WINDROSE
IUM-TT|^...^\
^•XJj """^-BERYLLIUM
u • ^s&
EAST GATE
WEST GATE
Map 1. On-Site Air Sampler Locations and Material Areas.
17
-------
34
RFP-ENV-71B
DIRECTIONAL
WINDROSE
FOR 1971 MONITORING
EAST/
ACCESS
ROAD
GREAT WESTERN RESERVOIR
A- AIR SAMPLER
- SPECIAL HIGH VOLUME GRAB SAMPLER
Map 2 Off-Site High-Volume Environmental Air Sampling Network
18
-------
RFP
-ENV-7TE
15
Hand ROCKY
FLATS
PLANT
Map 3. Programmed Environmental Air Sampling Network.
Map 4. Rocky Flats Effluent Water Flow.
A - DRAINAGE N°RTH WALNUT CREEK GREAT WESTERN RESERVOIR
C-DRAINAGE WOMAN CREEK
19
-------
RFP-ENV-71B
Table I. Radioactive Stack Effluent Releases, 1971.
(A) Plutonium
Monthly Concentrations (X 10"'1 /jCi/ml)
Building Jan Feb
771 0.005 0.005
774 0.015 0.010
776 0.004 0.095*
779 0.007 0.002
559 0.003 0.002
707 0.003 0.002
Total Releases by Month (MCi) 2.
852 17.240
| Applicable Standard: (Soluble 2 " Pu) = 0.06 X 1 0
Mar Apr
May Jun Jul
O.OOS 0.015 0.007 0.012 0.007
0.011 0.014 0.060" 0.013 0.008
0.033 0.006 0.018 0.011 0.003
0.002 0.002 0.002 0.002 0.002
0.002 0.002 0.003 0.003 0.003
O.OOS 0.003 0.005 0.004 0.003
8.017 5.989 8.286 5.838 2.671
1 MCi/ml.
Aug
0.006
0.007
0.003
0.002
0.002
0.004
2.680
Sep Oct Nov Dec
0.015 0.012 0.004
0.012 0.010 0.013
0.002 0.009 0.002
0.002 0.002 0.002
0.002 0.002 0.002
0.003 0.002 0.080
5.096 5.270 7.884
0.006
0015
0.002
0.002
0.002
"• 0.004
2.546
(11) Yearly Summary — Plutonium
Concentrations (X 10"" yCi/ml)
January — June
Buildin
771
774
776
779
559
707
Maximum
Concentration
(Single Sample)
0.015
0.109
0 087
0.006
0.004
0.004
(Monthly)
Average
Concentration
0.008
0.021
0.028
0.003
0.003
0.004
July -
Maximum
Concentration
(Single
Sample)
0.008
0.013
0.009
0.002
0.004
0.080
Total Plutonium Operations,
•The
MCl
maximum monthly average
emission (which
nil. The maximum smele samnle emission (G
December
(Monthly)
Average
Concentration)
0.002
0.0 II •
0,004
0.002
0.002
0.016
Yearly Summation:
occurred during filter changing operations in
.10 X 10"11 uCi/ml
) was from Uuildint: 774.
Total
Concentration
Max.
(Bldg)
0.015
0.109
0.087
0.006
0.004
0.080
0.109
Buildin
It must
Av.
(Bldg)
0.008
0.016
0.016
0.002
0.002
0 010
0.009
Year
% Std.
(Av.
Cone.)
13.3
26.7
26.7
3.3
3.3
16.7
15%
Total
Release
(vCi)
26.427
6.034
33.052
0.344
0.766
7.726
74.349
g 776 in February ) was 0.095 X 10
be noted that
1 3
at the stack, UKPORLC appropriate atmospheric dilution. The standards apply at the pl.inl perimeter and are in terms of averages of up to
one year. The annual average Pu emis.sion from ALL Pu operations was 0.009 X 10'1: nO/ml, about \*>% of the applicable standard
(0.06 X It)"12 ^Ci/ml).
** Filter changing operations.
***fcffluents leaking around one stage of filter plenum. Discovered and corrected.
(C) Uranium
Monthly Average Concentrations
lotal Hole
Building
444
447
881
883 (A)
883 (11)
886
889
865
991-1
ise hy Miinlli (A"l'i)
(X IO'13 MCi/ml)
Jan 1'Cb Mar Apr
0.009 0.005 0.002 0.002
0.071* 0.070 0.029 0033
0.004 0.017 0.018 0.049
0.010 0.008 0.010 0.012
0.010 0.006 0.003 0.004
0.00.1 0.001 0.002 0.002
0.003 0.002 0.002 0.002
0.002 0.001 0.002 0.002
0.002 0.002 0.001
1 I.2ft4 12.148 8.959 21.9.15
May
0.002
0.040
0.005
0.041
0.008
0.002
0.002
0.002
0.001
10.052
Jun
0.002
0.023
O.OOS
0.034
0.005
0 002
0.002
0.002
0.002
7.270
Jul Aug
0.002 0.002
0.002 0.017
0.005 0.006
0.008 0.013
0.003 0.003
0.002 0.002
0.002 ' 0.002
0.002 0.002
0.002 0.002
2.9 7ft ft. 149
Scp
0.001
0.030
0.002
0.013
0.002
0.001
0.001
0.001
0.001
4.405
Ocl
0,001
0018
0,002
0.010
0.002
0.001
0.00.1
0.001
0.001
3.1 SI
Nov
0.017
0 007
0.003
0.015
0.003
0.003
0.002
0.001
0.001
6.801
Dec
0.002
0.021
0.002
0.011
0.002
0.003
0.003
0.001
0.001
3.741
[Applicable Standard:*" (Soluble !1"ll) .) X HI l2 »iCi/nil|
(D) Yearly
Summary — Uranium
Concentrations (X 10"' 3 yCi/ml)
Building
444
447
881
883A
882B
886
889
January
Maximum
Concentration
(Single Sample)
0.009
0.077
0.050
0.040
0.012
0.004
0.005
- June July -
(Monthly)
Average
Concentration
0.004
0 044
0.016
0.019
0.006
0.002
0.002
Maximum
Concentration
(Single Sample)
0.017
0.033
0.006
0.014
0.003
0.004
0.003
December
(Monthly)
Average
Concentration
0.004
0.016
0.003
0.012
0.002
0.002
0.002
Tot
Concentration
Max.
(Bldg)
0.017
"0.077
0.050
0.040
0.012
0.004
0.005
Av.
(Bldg)
0.004
0.030
0.010
0.016
0,004
0.002
0.002
al Year
%Std.
(Av
Cone
O.I
1.0
0.3
0.5
O.I
O.I
O.I
.)
Tolal
Release
O'Ci)
9.960
25.756
35.440
20.680
5.740
0.132
0.146
-------
Table I. Radioactive Stack Effluent Release, 1971 (continued).
(D) Yearly Summary - Uranium (continued)
RFP-ENV-71B
Building
895
991-T
January —
Maximum
Concentration
(one month average)
0.004
0.007
June July — December
(Monthly)
Average
Concentration
0.002
0.002
Total Uranium
Maximum
Concentration
(one month average)
(Monthly)
Average
Concentration
0.001 0.001
0.007 0.001
Operations, Yearly Summation:
Tot
Concentration
Max.
(Bldg)
0.004
0.007
0.077
Av.
(Bldg)
0.002
0.002
0.008
1 Year
% Std.
(Av.
Cone.)
0.1
O.I
0.3
Total
Release
(MCi),
0.803
0.033
98.690
'Maximum monthly average emission 0.071 X 10"'* tiCi/ml (Building 447, January)
"Maximum single sample concentration. Both maximums associated with filter changes in the plenums of this building.
***Although Rocky Flats effluents would include several isotopes of uranium, the guideline for soluble-238 is the most restrictive in air. It
must be noted that this standard applies at the plant boundary and is in terms of yearly averages to an individual in the general population.
The values here, all well below that standard, are taken at the stack before any atmospheric dilution.
Table II. Non-Radioactive Stack Effluent Releases, 1971.
(A) Beryllium
Monthly Average Concentrations (X 10"6 mg/M3)
Building
444-447
883A
779
774
865
Total Monthly Release (grams)
(D) Annual Summary
Beryllium Stack Effluent Releases (X I0~' mg/M3)
Building
444.447
883A
779
774
865
Jan
2.2
1.0
0.3
0.8
0.5
0.8226
Feb
5.1
3.2
0.7
0.6
2.0
2.0923
Mar
3.0
0.5
0.3
0.6
0.4
1.2391
Apr
2.2
0.2
0.3
0.5
0.2
0.6988
May
1.8
0.2
0.3
0.5
0.5
0.6192
Jun
0.7
0.2
0.3
0.5
0.5
0.3700
Jul
15.0
0.5
0.3
0.4
0.2
4.4909
Aug
2.0
0.2
0.5
O.6
6.2
0.8021
Sep
2.8
1.1
0.2
0.2
0.2
0.8809
Oct
1.2
0.2
0.6
0.4
I.I
0.5191
Nov
0.2
0.2
3.6
0.8
0.2
0.0940
Dec
14.1
0.2
0.6
O 8
0.2
4 2010
Janu<
Maximum
Single-Sample
Concentration
45.0
25.2
5.1
2.4
9.8
iry — June July -
Average
Concentration
t.
2.6
0.6
0.4
0.7
1.0
Maximum
Single-Sample
Concentration
209.2
1.2
7.7
0.4
7.0
December
Average
Concentration
5.8
0.5
0.9
0.2
0.4
Total Beryllium Operations, Yearly Summation:
Max.
Cone.
209.2
25.2
7.7
2.4
9.8
209.2
Totals
Av.
Cone.
4.2
0.6
0.6
0.5
0.7
1.3
for Year
*% Std
42
6
6
5
7
13.0
Total
Release
(g)
15.1879
0.0793
0.0262
0.8146
0.7220
Total
16.8301
•Applicable Standard is 10X10' mg/M3 (Division Internal Goal is 5 X 10 * mg/M3).
21
-------
RFP-ENV-71B
Table III. Average Monthly Air Sample Concentrations, On-Site, Radioactive.
(A) Total Long-Lived Alpha Concentrations (U, Pu, and natuVally occurring alpha emitters)
Monthly Average Concentrations
Location
S-l
S-2
S-3
S-4
S-5
S-6
S-7
S-8
S-9
S-10
S-SO
S-51
Jan
0.0044
0.0045
0.0033
0.0021
o.oon
0.0031
0.0082
0.0058
0.0043
0.0046
0.0042
0.0044
Feb
0.0033
0.0044
0.0028
0.0044
0.0040
0.0030
0.0066
0.0069
0.0040
0.0052
0.0026
0.0051
(X 10'l! MCi/ml)
Mar
0.0046
0.0039
0.0033
0.0047
0.0032
0.0028
0.0054
0.0078
0 0041
0.0041
0.0045
0.0036
|Applicable Standard (Soluble Plutonium-239)
(B) Summ
jry: Total
Long-Lived
Apr
0.0036
0.0046
0.0059
0.0067
0.0036
0.0037
0.0082
0.0324
0.0039
0.0072
0.0085
0.0067
= 0.02 x
May
0.0057
0.0050
0.0052
0.0042
0.0047
0.0052
0.0043
0.0090
0.0036
0.0047
0.0048
0.0046
Jun
0.0052
0.0027
0.0048
0.0040
0.0060
0.0034
0.0047
0.0103
0.0042
0.0073
0.0078
0.0037
Jul
0.0034
0.0025
0.0054
0.0046
0.0053
0.0145
0.0026
0.0096
0.0043
0.0029
0.0052
0.0024
Aug
0.0040
0.0055
0.0066
0.0041
0.0026
0.0020
0.0034
0.01 10
0.0036
0.0030
0.0086
0.0020
Sep
0.0045
0.0029
0.0057
0.0035
0.0034
0.0032
0.0022
0.0056
0.0026
0.0040
0.0059
0.0041
Oct
0.0049
0.0044
0.0052
0.0034
0.0058
0.0021
0.0034
0.0128
0.0028
0.0062
0.0076
0.0054
Nov
0.0035
0.0040
0.0046
0.0034
0.0069
0.0068
0.0012
0.01 14
0.0013
0.0040
0.0064
0.0044
10" uCi/ml
Alpha, Cm-Site, 1971
Dec
0.0038
0.0047
0.0043
0.0034
0.0034
0.0030
0.0045
0.0071
0.0049
0.0038
0.0036
0.0056
Concentration (X 10"1! >iCi/ml)
Location
S-l
S-2
S-3
S-4
S-5
S-6
S-7
S-8
S-9
S-IO
S-50
S-51
Yearly Summation,
Total Averages:
No. of Samples
243
241
245
244
245
245
245
245
244
237
244
244
2922
tc
0.0034
0003S
0.0023
0.0024
0.0037
0.0083
UD
00050
0.0038
22
-------
89
RFP-ENV-71B
Table IV. Average Monthly Air Sample Concentrations, Off-Site, Radioactive, (continued).
(A) Low-Volume Programmed Samplers
2. Yearly Summary, Long-Lived Alpha Concentrations (U, Pu, and naturally occurring alpha emitters)
Concentrations (X 10"'2 MCi/ml)
January — June
Location No. of Samples
Boulder (S-l 5)
liroomfield (S-l 7)
Coal Creek (S-l 1)
Denver (S-23)
Golden (S-20)
Lafayette (S-l 6)
Marshall (S-l 3)
Wagner (S-l 8)
Westminster (S-25)
Summary:
46
46
46
46
46
46
45
46
42
409
-------
RFP-ENV-71B
Table V. Special High Volume Air Samples, On- and Off-Site, Radioactive.
(A) On-site Grab Samples*
Plutonium Concentrations (X 10~l:uCi/ml)
Location
of Grab Jan I-eb Mar Apr May Jun
Jul
Aug
Sep
Nov
Dec
903-20 0.00039 0.00109 0.00055 0.00158 0.00135 0.00234 0.00054
903-15 0.00004 0.00192 0.00029 0.00307 UD** 0.00220 0.00324
903-10 0.00039 0.00176 0.00109 0.00162 0.00018 0.00132 0.00090
903-5 0.00011 0.00175 0.00030 0.00088 0.00042 0.01370 0.00067
Yearly Summation:
Location
903-20
903-15
903-10
903-5
Totals (aven
Single
Sample
Maximum
0.001800
0.002970
0.001 110
0.004960
iges)
Average
Concentration
O.OO0200
0.000261
0.000104
0 000187
0.00313 0.00373
0.00962 0.00852
0.00060 0.00120
0.00218 O.00051
Percent of
Standard* ** *
0.00161 O.O0216 0.00508
0.00123 0.00019 UD
UD 0.001 II 000272
NA"« 0.00325 0.00196
0.00013
3.3
4 4
1.7
3 1
2.27c
Number
of
Samples
48
46
44
42
Number
Less Than
Detection
Limits
12
18
13
12
•Taken just to east of asphalt pad covering contaminated soil on plant site.
"Undetectable (below detection limits).
•••No analysis.
•"•Standard forthese on-sitc samples is taken as 0.06 X 10"" uCi/ml.
(B) Off-site Grab samples
Concentrations (X 10"'a MCi/ml).
Location
of Grab Jan Feb Mar Apr May Jun
Jul
Aug
Sep
Oct
Nov
Dec
Wagner 0.00038 0.00220 0.00120 0.00306 0.00145
Coal Creek NA 0.00390 0.00153 0.00213 O.OO078
Yearly Summation:
Single
Sample
Location Maximum
Wagner 0.00570
Coal Creek 0.06020
0.00340 000214
0.01455 0.00141
Average
Concentration
0.000345
0.000344
0.00375 0.00743
0.00318 0.00510
Percent of
Standard
17.2
17.2
001827 0.00040 0.00185
0.00015 0.00091 0.00278
Number
of
Samples
42
35
Number
Less Than
Detection
Limits
7
8
Totals (averages)
0.000266
13.3
15
Table VI. Beryllium Concentration in Air Samples.
Concentration (X 10"' mg/M3)
% of Standard'
Jan
Feb
Mar
Apr
May
Jun
Summary
Jul
Aug
Sep
Oct
Nov
Dec
Summary
On-Site
.009
.012
.012
.010
.020
.010
.012
.007
.010
.613
.014
.010
^010
.012
Off-Site
.010
••.187
.011
.012
.015
.012
.041
.017
.011
.009
.025
.011
.011
.014
On-Site
9
12
12
10
20
10
12%
7
10
23
14
10
10
12%
Off-Site
10
••187
1 1
12
IS
12
41%
17
11
9
25
1 I
11
14%
•Beryllium standard in ambient air is 1 X 10"! mg/MJ - Rocky Flats self imposed standard is'/j that or 0.5 X 10"' mg/M'.
••This concentration represents cross contamination in the analytical laboratory.
24
-------
RFP-ENV-
Table VII. Dustfall Samples, 1971 Yearly Summary.
Arvada
Broom field
Boulder
Coal Creek
Denver
Eastlake
Golden
Lafayette
Marshall
Superior
Wagner
Westminster
Summary
Berthoud
Castle Rock
Summary
No.
Taken
23
22
18
19
22
23
•22(21)
22
23
21
20
22
•257 (256)
7
9
16
Samples,
Less Than
Detection
Limit
4
11
14
11
1 1
11
8
13
10
8
6
7
114
2
7
9
(Plutonium)
Sample
Days
362
348
334
292
341
362
•348(334)
348
362
334
292
341
•4064 (4050)
668
1971
Maximum
(Single Sample)
Concentration
(pCi/M2)
16.1 I
28.88
28.59
21.66
53.87
6.00
•(174.16)
11.77
67.70
16.1 1
13.17
17.30
•(174.16) (67.70)
5.58
2.46
Total
Deposition
(pCi/M')
77.44
74.48
85.69
50.76
118.27
49.84
•219.55 (45.39)
46.26
149.04
74.20
9.61
41.36
•996.50 (822.34)
12.98
7.73
Deposition Rate
5.30
3.21
1.71
2.20
5.20
2.15
•12.04(2.65)
' 1,63
6.98
4.13
0.69
2.48
•4.09(3.38)
0.90
0.14
5.28
20.73
0.41
•Based on highly suspect data. The removal of one single-aliquot sample reduces the total deposition at Golden to 45.39 pCi/M1 and the total
(summary) deposition rate to 3.38 pCi/M1 /month.
Table VIII. Water Surveys.
(A) Radioactivity in Holding Ponds and Effluent Waste Water
I Pond B-4 (Effluent Waste Water)
Concentrations (X 10"'
U + Pu
Concentrations
• Effluent
Volume
Sample No. (million
Period Samples liters)
January 4 36.01
I;ebruary 4 34.85
March 4 49,18
April 5 41.21
May 4 32.36
June 5 28.15
July 5 23.95
August 4 30.47
September 5 33.69
October 4 42.64
November 4 47.61
Pecember 5 53.79
( ) denotes suspect data. NA - No Analysis
Max.
36.64
27.73
19.19
19.29
19.98
10.30
8.95
18.75
11.19
5.75
(15.08)
(28.89)
Avg.
14.33
24.74
13.15
14.75
12.54
8.33
6.14
11.34
7.14
5.61
10.67
11.48
Release
(mCi)
0.516
0.862
0.647
0.608
0.406
0.234
0.147
0.346
6.241
0.239
0.508
0.618
I'u
Concentrations
Max.
4.01
7.23
4.32
5.23
4.59
2.61
6.09
2.77
7.04
1.59
0.98
1.56
Avg.
2.29
2.92
2.86
2 99
2.63
1.60
2.92
1.05
2.72
1.01
0.59
1.09
Release
(mCi)
0 082
0.101
0.141
0.123
0.085
0.045
0.070
0.032
0.092
0.043
0.028
0.059
Am
Concentrations
Avp.
3.07
I 20
1.89
1.51
0.94
1.37
1.03
0.42
0.65
0 Ofi
NA
NA
Max.
1.36
2.67
2.J9
2.26
2 18
1.29
0.52
1 OH
0 16
NA
NA
2, Yearly Summation Pond B-4 (Effluent Waste Water: Total Volume 1971 = 232,150,000 Liters)
Concentrations (X 10"' jiCi/ml) i
V + I'u
Pu
Am
Sample
Period
Jan-Jun
Jul-Dec
Summary
Number
Samples
Taken
26
27
53
Concentrations
Max.
36.64
(28.89)
36.64
Avg.
14.64
8.73
11.69
Release
(mCi)
3.273
2.098
5.371
Number
Samples
Taken
26
27
53
Concentrations
Max.
7.23
6.09
7.23
Avg.
2.55
1.56
2.06
Release
(mCi)
0.577
0.324
0.901
Concentrations
Max.
3.07
1 29
3.07
Avg.
1.50
0.53
1.00
Release
(mCi)
0.378
0.063
0.441
25
-------
RFP-ENV-71B
Table VIII. Water Surveys (continued).
(A) Radioactivity in Holding Ponds and Effluent Waste Waters
3. Grab Water Samples - Ponds A and C (Holding Ponds)
Pond (A) X 10"' uCl/ml
No. Samples Concentrations N(
Taken . Samples Concentrations
-------
93
RFP-ENV-71B
Table VIII. Water Surveys (continued).
(A) Radioactivity in Holding Ponds and Effluent Waste Waters (continued)
4. Walnut Creek at Indiana Water Samples (Rocky Flats Effluent Water Course) (continued)
Yearly Summation
Concentrations (X 10"' uCi/ml)
U + I'u
Pu
Concentrations
Max.
49.34
Avg.
11.55
%of~
Standard'
0.24
Concentrations
Min.
0.41
Max.
8.47
Avg.
2.56
%of
Standard2
0.15
Concentrations
Mm.
0.01
Max.
4.39
Avg.
0 80
%of
Standard1
0.06
pu
MPC
where MPC,j = 10,000 X 10"' »iCi/ml
and MFC
= 1,667 X 10"'
pu an Pu
2 Based on the soluble ! 3' Pu in water standard of 1 667 X 1 0"' MCi/ml.
'Based on the soluble J41 Am in water standard of 1333 X 10"' MCi/ml.
(B) Radioactivity in Reservoirs and Tap Water Samples
1. Reservoir Water Samples
Concentrations (X 10"' MCi/ml)
January - June 1971
Location
Baseline Reservoir
Great Western Reservoir
Ralston Reservoir
Standley Reservoir
U + Pu
Pu
Am
Number
Samples
Taken
12
12
12
12
Concentrations
Max
6.06
6.29
28.79
17.44
Avg.
3 25
3.12
20.50
5.22
Number
Samples
Taken
11
10
10
9
Concentrations
Max.
1.68
0.64
0.04
0.95
Avg.
0.33
0.14
UD*
0 30
Number
Samples
Taken
4
_
1
Concentrations
Max.
1.13
_
0.10
Avg
0 60
_
0.10
July - December 1971
Location
Baseline Reservoir
Great Western Reservoir
Ralston Reservoir
Standley Reservoir
-i Pu
Pu
Am
Number
Samples
Taken
7
9
11
10
Max
6.92
16.06
22.04
5.16
Avg.
3.63
2.97
10 29
3.22
Number
Taken
7
10
8
10
Sam pies
-------
RFP-ENV-71B
Table VIII. Water Surveys (continued).
2. Community Tap Water Samples
January - June 1971
Concentrations (X 10"' »iCi/ml)
Arvada
Boulder
Broomfleld
Denver
Golden
Lafayette
Louisville
Thornton
Westminster
U + Pu
Number Samples
Taken
0.45
0.77
0.52
0.30
0.60
itions
Avg.
0.45
0.23
0.98
0.36
0.09
0.22
0.21
0.18
0.27
(B) Radioactivity in Reservoirs and Tap Water Samples (continued)
July - December
1971
U + Pu
Number Samples
Arvada
Boulder
Broomfield
Denver
Golden
Lafayette
Louisville
Thornton
Westminster
Taken
11
11
11
11
11
9
10
10
10
-------
Table VIII. Water Surveys (continued).
95
RFP-ENV-71B
(C) Semiannual Water Collection (Summary, 1971)
Concentrations X 10"' nCi/ml
No. U + Pu Concentrations
Location
S Miles
Summary
Samples
14
16
30
Mm.
0.55
j.09
0.55
Max.
16.34
34.40
34.40
Avg.
3.32
5.85
4.70
1 The standard for a soluble mixture of U 4- Pu in water is
%of
Standard'
0.06
0.07
0.06
-Pu
No.
Samples
13
16
29
Pu Concentrations
0.05
0.08
0.05
MPC
U
MPC
<1
Pu
2 The standard for soluble 2 3' Pu in water is 1,677 X 10"' uCi/ml,
(D) Chemical Concentrations in Holding Ponds and Effluent Waste Waters
Max.
2.76
0.92
Avg. Standard1
0.41
0.25
0.32
0.02
p^OI
0.02
Where: MPC,j is 10,000 X 10"' uCi/ml
and MPCpu is 1,667 X 10"* "Ci/ml
1. Pond B-4
Sample
Period
Average Concentration (mg/l)
January
February
March
April
May
June
Summary
July
August
September
October
November
December
Number
Samples
20
20
22
19
19
22
122
21
22
21
21
20
21
Summary 126
"'Dissolved oxygen.
Range of
PH
7.3-8.0
7.4-7.6
7.2-7.9
7.2-7.8
7.6-8.4
7.7-8.5
7.2-8.4
7.2-8.2
7.1-9.6
7.2-7.9
7.1-8.1
7.2-7.7
7.2-7.8
7.1-9.6
N03"
16.7
6.2
9.4
8.4
5.5
3.8
8.3
3.4
4.1
3.6
7.2
7.1
4.9
5.1
PO4"3
10.9
9.2
6.3
4.3
12.5
13.3
9.4
8.9
7.9
15.4
20.7
22.6
17.2
15.4
F~
0.5
0.4
0.4
0.4
0.4
0.5
0.4
0.4
0 4
0.4
0.4
0.7
0.4
0.4
BOD,
5.4
9.9
4.5
6.4
5.8
7.3
6.6
NA
8.2
7.9
6.7
4.2
6.0
6.6
DO'"
26.3
10.8
10.8
11.0
9.9
10.3
13.2
4 4
4.4
5.3
6.2
8.8
9.2
6.4
Total
Solids
400
(681)
406
392
456
368
450
NA
NA
260
309
393
332
324
Cr"
6
38.8
450
324
392
<500
78.4
<0.005
<0.005
<0.005
-------
RFP-ENV-71B
Table VIM. Water Surveys (continued).
(E) Chemical Concentrations in Holding Ponds and Effluent Waste Waters
1. Pond Grab Water Samples
Monthly Averages (mg/1)
Pond A
pH
January 7.8
February 7.6
March 7.5
April 7.8
May 7.9
June 8.0
Summary 7.8
July 7.8
August 9.2
September 8.5
October 7.6
November 7.8
December 7.7
Summary 8.1
•NA Is no analysis.
2. Yearly Summary
NO,-
11.1
13.7
19.6
29.7
85.0
20.1
29.9
23.0
23.4
36.3
52.9
58.9
78.6
45.5
- Pond A
PO.-J
0.6
1.1
0.6
0.7
0.6
0.6
07
0.6
0.6
0.6
0.4
0.6
0.6
0.6
F-
0.4
0.4
0.4
0.4
0.4
0.4
0.4
0.3
0.4
0.4
0.4
0.5
0.4
0.4
Total
Solids
173
101
164
183
393
233
208
•NA
NA
300
384
429
488
267
Cr"
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
Elemental Analyses
(Yearly Summary)
Applicable Std.
% of Standard
Number
Samples
10
(2)
3. Yearly Summaty - Pond C
(Yearly Summary)
Applicable Std.
% of Standard
10
(2)
As
0.01
0.05
20%
0.01
0.05
20%
Ba
0.01
1.00
1%
0.01
1.00
1%
Be
O.OOOS
0.0002
PondC
PH
7.8
7.7
7.5
7.5
&.0
7.8
7.7
7.8
8.4
8.5
8.2
8.1
7.7
8.1
NOj"
0.5
0.9
0.4
0.4
0.3
0.3
0.5
0.3
0.6
1.2
1 3
1.5
0.9
1.0
PO4"3
0.6
1.3
0.6
0.6
0.6
0.6
0.7
0.6
0.6
0.6
0.6
0.6
0.6
0.6
F-
0.4
0.4
0.4
0.4
0.4
0.4
0.4
0.3
0.4
0.3
0.4
0.8
0.4
0.4
Total
Solids
243
212
205
249
212
188
228
NA
NA
175
227
185
194
195
Cc"
<0.005
<0.005
-------
97
RFP-ENV-71B
GREAT WESTERN RESERVIOR
U.S. AEC RESERVATION
I
2.0- 1.0uCi/m:
ROCKY FLATS
PLANTSITE
0.1 -0.05MCi/m2
0.35 - 0.1 MCi/m2 MOWER RES RVOIR
STANDLEY LAKE
INDIANA STREET
Table X. Surface Soil Analysis: off-site contours.
NOTE: These contours were empirically derived by means of a computer
curve-fitting program using the method of least squares. This
results in a mathematical expression for grid sectors, giving the
. . activity of the plutonium in the soil as a function of radial distance
from the on-site barrel-storage area. Three hundred forty-two
soil samples were used in generating these contours. Eighteen
samples were taken by the Colorado Committee on Environmental
Information, 18 by U.S. AEC Health and Safety Laboratory,
306 by the Rocky Flats Health Physics Department. The
values assume a soil density of 1 g/cm3 at a depth of one
centimeter.
Table XI. Vegetation Samples 1971.
Concentrations (X 10"' MCi/gram-Dry)
<1 Mile
1-5 Miles
>5 Miles
Summary:
June 1971
No. Samples
Taken
12
42
23
77
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98
RFP-ENV-71B
VI. Summary and Conclusions
The principal protection for our environment must be'provided at the very
source of potential degradation and/or potential pollution. No program can
replace adequate controls at the source: any environmental program is
after the fact.
Environmental Protection Must Be At
Source.
This is especially true for radioactive isotopes. Rocky Flats is working toward
total containment of radioactive materials. The data contained in this report
are the result of the controls employed at this plant site and do not in any
way describe those complex controls in themselves. That these controls are
effective can be seen by comparing releases with those established standards
over the applicable time periods.
Data are not meaningful without a frame of reference. It is appropriate to
provide some background information to better understand this report.
The State of Colorado and the immediate environs of Rocky Flats are most
interesting from a radiological point of view. For example, water taken from
wells in Maine has about 3000 times the natural radioactivity as that taken
from the Potomac River near Washington, D.C. But even that level is low
when compared with water taken from wells near Boulder (or, for that
matter, Joachimsthal, Czechoslovokia) where natural radioactivity concen-
trations are 10,000 times that amount.16 Rocky Flats receives its water from
Ralston Reservoir near Golden. Background radiation surveys indicate that
this water is higher in gross alpha content when it enters the plant than when
it is released as effluent after being used to process radioactive materials.
Rocky Flats Working Toward Total
Containment of Radioactive
Material
Frame of Reference for Data.
Water From Wells Near Boulder
Has 10,000 Times Natural
Radioactivity as Water From
Potomac Near Washington D.C.
Rocky Flats Plant
ROCKY FLATS
Effluents (the same water)
Average 12 x 10"9 nC\/m\
Water coming into Rocky Flats is higher in Gross Alpha
Concentration than the same water when released as effluent.
Residents of Colorado receive an annual cosmic ray dose of about 120
millirem, about three times that received by the average resident of California
(40 mrem) and about twice the annual gamma ray dosage from naturally
occurring terrestrial radioactivity.4 In fact, a 1971 survey released by the
EPA showed that Colorado has the highest natural radiation levels in the U.S.
1971 EPA Survey Shows
Colorado Has Highest Natural
Radiation Level in U.S.
32
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99
RFP-ENV-71B
It is well known that the contribution of man-made radiation (other than
medical) to the total population dose has been only a small fraction of the
contribution from background radiation; in fact, it is even smaller than the
natural fluctuations in that background.6 Even this background level of
about 130 mrem per person per year (about twice that high in Colorado) has
not shown any adverse effects on man.
Studies to date indicate that radiation at or below occupational levels (at
least ten times higher than standards for the general populace) has not been
shown to be harmful. Comparisons between about 35,000 workers who
received approximately 50,000,000 mrem over 25 years and the general
population show that the radiation workers had a 25% lower leukemia rate;
a 42% lower malignant death rate; and a 46% lower death rate from all causes
in each male and female age group. The conclusion to this study was,
"All one can deduce from these various studies is that there is no indication
of any health hazards to any employed."17
More specifically, the average annual death rate due to cancer in the U.S. is
130 deaths per 100,000 people.18 The average annual death rate for the
employees at Rocky Flats is 52 deaths due to cancer per 100,000 population,
or less than half that of the general population.
Man-Made Radiation Contribution To
Total Population Dose is Even Less Than
Natural Fluctuations in Natural Back-
ground Level.
Radiation Levels at Least 10 Times
Higher Than General Population Standards
Has Not Been Harmful: Exposure to
Ten Times General Population Standards
Showed Lower Leukemia Rate, Malignant
Death Rate, and Total Death Rate Than
General Population.
Present Data Indicate Rocky Flats
Death Rate Due to Cancer Less Than
One-Half That For General Population.
It should be noted that this represents a small statistical sample and the only
conclusion that can be drawn is that there is no evidence of any adverse
effects to the Rocky Flats employees. A continuing effort exists to gather
more data on all workers in this field. Rocky Flats is actively cooperating
with the U.S. Transuranium Registry in this study.
There is one important distinction to be made at this point. The terms
pollution and contamination are often, although incorrectly, used inter-
changeably. Pollution must be defined as concentrations of foreign material
in excess of normal values. This concentration, in air, water, soil, etc., must
have an adverse effect on man to be a true pollutant. A contaminant is that
material, not normally found, but where present can be attributed to man's
activities. Environmental contamination, while definitely not desirable, is
still not necessarily pollution unless that contaminant can and does have an
adverse effect on man or some other life form.
Contamination vs Pollution.
Following a fire at Rocky Flats in May 1969, intensified soil and monitoring
surveys disclosed some soil contamination in the vicinity of the plant site,
primarily to the east of the perimeter fence. Subsequent investigations
indicated that no measurable radioactive contamination had escaped from
the buildings involved in that fire, and that the primary source of contami-
nation had come from waste drums of contaminated oil stored near the east
fence. Since it is felt that some resuspension of this material is inevitable,
even though the most affected area is now covered with a thick asphalt pad,
steps have been taken to reduce thfs possibility to an absolute minimum.
No Measurable Radioactive
Contamination Released in 1969
Fire.
Soil Contamination
The affected areas are under constant surveillance. The contours in
Table X have been empirically derived using the best data available from all
sources, i.e., the U.S. AEC Health and Safety Laboratory and the Colorado
Committee for Environmental Information, as well as the surveillance
activities of the Rocky Flats Health Physics Department.
33
-------
RFP-ENV-71B
Rocky Flats is committed to a soil sampling program. This program requires
that samples be taken at a minimum of 6 months. At the present time,
however, soil samples are being taken more frequently.' Constant evaluation
of the data thus generated shows no significant change in the contours.
Dustfall samples taken from the surrounding area may well represent some of
this contaminated material that has been resuspended. Wind in the vicinity of
Rocky Flats could deposit very small quantities of this material in the
Boulder, Golden, Marshall, and Coal Creek areas. Dustfall sampling in these
areas indicate that this may very well be the case. There are, however, other
factors that might be creating anomalies as great as or even greater than any
contribution from Rocky Flats. Wind currents, sweeping down through
Boulder and Coal Creek Canyons, and along the Front Range, could be
depositing greater than to be expected concentrations of materials associated
with world wide fallout* in these areas. It Must Be Emphasized that these
Concentrations, Even Including Any Contributions from Rocky Flats, Are
Still on the Same Order of Magnitude as that to Be Expected from World
Wide Fallout,1* and, as such, Provide no Known Health and/or Safety Hazard
to the Public. There is probably a very real contribution from Rocky Flats.
This contribution is so low as to provide no significant exposure risk to the
population in the area. Ways of reducing this contribution are, however,
under intensive study.
Dustfall Samples, Even Including
Rocky Flats Contribution (If Any)
Still Same Order of Magnitude As
World Wide Fallout - No Known
Health and/or Safety Hazard to
the Public.
The Water Quality Office of the Environmental Protection Agency conducted
their own independent study of the environment and especially the water
courses and effluents from and around Rocky Flats. The conclusion stated
in that report20 was as follows:
"Monitoring data do not indicate any public health hazard
associated with the routine discharge of radioactive wastes to
*
Walnut Creek. There has been no measurable degradation of
(Rocky Flats) plant origin in the radiological water quality
of Great Western Reservoir, the source of public supply for
the City of Broomfield. This reflects the general adequacy of
the liquid waste management program carried on at the Rocky
Flats Plant. In this respect, additional abatement requirements
are not indicated at this time."
WOO of EPA Studied Rocky Flats and
made Conclusion:
In that report, the EPA did, however, make some recommendations. Those
recommendations and the response to them are included as Appendix A to
this report.
Total plutonium releases during 1971 by both stack effluent discharge and
effluent water release were a total of 0.975 millicuries (0.016 grams).
Total uranium releases, which include relatively high concentrations of
naturally occurring isotopes, were about 5 millicuries. Total beryllium
released during the entire year was about 17 grams.
Total Plutonium Releases During 1971
were 0.975 mCi (0.016 grams)
Total Uranium Releases (Including
Naturally Occurring Isotope) About
SmCi. Total Beryllium About 17 grams.
'Fallout is actually the radioactive debris from nuclear weapons tests conducted in the atmosphere. It essentially consists of fission products,
unexpended fissile material such as plutonium and uranium, and activation products. These radioactive products, vaporized and blown into
the atmosphere by the tremendous force of the explosion, condense to form paniculate matter that, when it finally falls to the earth, is
called fallout. Fission products from nuclear explosions have been in the atmosphere for more than 25 years. The lifetimes of the various
radioactive materials in fallout can range from fractions of a second to many years and thus make actual empirical measurement quite
I g
complex.
34
-------
RFP-
ETJV-71B
Plutonium stack effluent releases from Rocky Flats have, on a single sample
or single-month-maximum basis, exceeded both recomfnended guidelines,
and especially internal plant goals for limiting effluent concentrations. The
same is true, although less frequently, for beryllium and uranium releases.
Although insignificant in terms of the yearly average concentrations,
methods to limit and control these releases are being studied.
Beryllium and Uranium Releases Have
Exceeded Guidelines on Single-Sample,
but not Applicable Average Basis.
The primary reason for these higher-than-ordmary releases has been the system
employed in changing filters in the exhaust plenums of process buildings.
The time interval and the physical implementation of better techniques for
these filter changes is under intensive study.
Studies Under Way on Filter
Changes to Better Limit Extraordinary
Releases.
The material contained in this report has been released on a monthly basis
to the Colorado Department of Health, and the regional office of the
EPA. In addition, the state agency maintains its own survey and monitoring
procedures.
Material Contained in This Report
Released monthly to Colorado Depart-
ment of Health and Regional EPA
Office.
Analyses of over 50,000 samples have shown the ambient levels of radioactivity
in effluents from Rocky Flats to be below even the most restrictive standards
available. Rocky Flats personnel are continually striving to reduce these
levels even further by providing valuable technological and innovative
advances in the field of nuclear materials control and safeguards. The
Health Physics Department has recently been administratively joined with
the research function to create a totally new group concept, that of Health
Physics, Research and Ecology. We hope this will lead to even better
communications of advances and pertinent information to the public at
large as well as to the scientific community. The goal of this and every
other group at Rocky Flats as well as the nuclear industry as a whole, must
be to reduce radiation releases even lower than the current insignificant
levels. As technology in the field has increased, emissions have gone down
and this trend will continue.
Over 50,000 Environmental Samples
Analyzed: Rocky Flats Effluents
Below Standards.
Health Physics Joined with Research
New Group; Health Physics, Research
and Ecology.
As a pionper in the field of nuclear materials. Rocky Flats will have a
valuable part to play in this essential transition by providing experience and
information. And, as more and more knowledge is gained in the field.
Rocky Flats will be able to take advantage of a wider range of technology to
better protect its own environs.
Rocky Flats is Pioneer in Nuclear Materials.
i
Increased Technology will Help Rocky
Flats Reduce Emissions Even Further.
Rocky Flats has an essential part to play in the defense of this country and
of our way of life. It has an equally important part to play as an integral
part of the business and industrial community of Colorado, and as a good
neighbor to the people in the area.'
Rocky Flats Impact.
In summation, then, while Rocky Flats has met and mostly surpassed its
goals for maintaining radioactive effluent emissions below the most restrictive
standards available, to do even better is the implicit goal of the entire
operation.
Rocky Flats Goal To Do Even Better.
35
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]02 RFP-ENV-71B
VII. Bibliography
1. Daneth, F. A., Radioactive Standards and Units, Nature. 166,931 (1950).
2. Oldenberg, O., Introduction to Atomic Physics, McGraw-Hill, 189, (1954).
3. Latt, R. E., and Andrews, H. L., Nuclear Radiation Physics. Prentice Hall, 303, (1963).
4. Basic Radiation Protection Criteria, NCRP Report No. 39, National Council on Radiation Protection and Measurements,
(1971).
5. Taylor, Launston S., Radiation Protection Standards, CRC Critical Reviews in Environmental Control, April, 1971.
6. Liberman, Joseph A., "lonizing-radiation Standards for Population," Physics Today, November 1971.
7. AEC Manual of Standard Procedures, Chapters 0510, 0524, United States Atomic Energy Commission,
Document No. NYO-4700 (1967).
8. Title 10 — Atomic Energy, Part-20 Standards for Protection Against Radiation, Code of Federal Regulations,
Chapter 1,11960).
9. Maximum Permissible Body Burdens and Maximum Permissible Concentrations of Radionuclides, in Air and in Water
for Occupational Exposure, National Bureau of Standards Handbook 69, U.S. Department of Commerce.
10. Cholak, J., Miller, L. H., Princi, F., Quarterly Progress Report on Toxicity of Beryllium, AMC-TR-7-665, (1960).
11. Federal Register, December 7, 1971.
12. Water Quality Standards and Stream Classification, Water Pollution Control Commission, Colorado Department
of Health (1971).
13. The Public Health Service Drinking Water Standards - 1962, U.S. Department of Health, Education and Welfare,
Public Health Service, (1969).
14. Hardy, E. P., and Krey, P. W., (Health and Safety Laboratory, U.S. Atomic Energy Commission), Determining the
Accumulated Deposit of Radionuclides by Soil Sampling and Analysis, Environmental Plutonium Symposium,
August 1971, Los Alamos Scientific Laboratory.
15. Langham, W. H., Plutonium Distribution Factors as a Problem in Environmental Science, LA-DC-12856, Los Alamos
Scientific Laboratory, Los Alamos, New Mexico, (1972).
16. Kastner, J., The Natural Radiation Environment, U.S.AEC, Division of Technical Information, (1968).
17. Hanford Environmental Health Foundation, Environmental Effects of Producing Electrical Power, Hearing before the
Joint Committee on Atomic Energy, Congress of the United States, Part 1 (October and November, 1969).
18. Rates obtained by telephone conversation with Mr. Edwin Silverberg, Project Statistician, Research Department,
American Cancer Society, Inc., New York, N.Y.
19. Peirson, D. H., Worldwide Deposition of Long-Lived Fission Products from Nuclear Explosions, Nature,
234 (November 12, 1971).
20. Water Quality Office, Environmental Protection Agency, Division of Technical Support, Radiological Activities Section,
Radioactivity Levels in the Environs of the Rocky Flats Plutonium Plant, Golden, Colorado 1970, (April 1972)..
36
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RFP-E
VIII. Appendix A
Recommendations of the Environmental Protection Agency, Water Quality Office Report on Rocky Flats, April 1, 1971,
and response to those recommendations.
Recommendation 1:
Routine analysis of suspended vs dissolved radioactive materials in the water samples from effluent to Walnut Creek and
Great Western Reservoir.
Response:
We are in the process of studying the nature of the plutonium found in our effluent and the
nature of the plutonium found in the ponds. Our initial studies (in conjunction with CSU)
indicate that much of the plutonium becomes incorporated with the algae. At this point we
have not been able to determine if it is a physical incorporation or a biochemical mechanism.
Algae vary in size over a wide range. It is difficult to ascertain how much is truly in solution
versus very small imdissolved suspended particles of plutonium dioxide incorporated into
small suspended algae. By using different size filters, one would obtain different answers. The
total amount of plutonium found is very small. As we learn more about the nature of the
plutonium carried in the effluent water we will be in a much better position to understand
any potential value which could be derived from separate routine analysis of suspended and
dissolved plutonium differentiated from routine analysis of the total plutonium found in the
water sample. We will continue to study this and keep the Water Quality Office of the EPA
informed of our progress and findings.
Recommendation 2:
In addition to gross alpha activity determinations, specific analyses should be conducted for plutonium-239 and uranium.
Response:
Specific analyses for plutonium-239 and uranium are being completed. This change was _
effective January 1970.
Recommendation 3: ,
At least annually, preferably semi-annually, levels of plutonium in the various trophic levels of the aquatic populations
inhabiting Great Western Reservoir and Standley Lake should be determined.
Response:
This recommendation requires an extensive full-scale research project. The first phase of this
project has been initiated in conjunction with Colorado State University. Phase One relates
to the settling ponds on the plant site. After the results of the first phase are interpreted, we
will proceed with studies on the various trophic levels of the aquatic populations inhabiting
Great Western Reservoir and Standley Lake. We intend to continue our program with Colorado
State University and also conduct more "in-house" studies on the aquatic systems of interest.
Perhaps, after the research programs are finished, we can develop some type of routine (annual
or semi-annual) measurement on the various trophic levels in the aquatic system. We will keep
the Water Quality Office of the EPA informed of our progress on these research programs.
37
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104
RFP-ENV-71B
Recommendation 4:
Semi-annual monitoring reports should be expanded to include data on effluent flow and radioactivity concentrations in the
effluent to the south fork of Walnut Creek. Sufficient data should be presented to permit the calculation of at least the
monthly amounts (curies) of plutonium and uranium (suspended and dissolved) discharged to the creek.
Response:
With the exception of separating suspended from dissolved activity (being studied), these types
of data are being incorporated into monthly reports furnished the Colorado Department of
Health. They are being included in semi-annual reports, copies of which are being forwarded to
the EPA.
38
-------
PREVIOUSLY PUBLIC'Y RELEASED
105
RFP-ENV-72
April 13, 1973
ANNUAL ENVIRONMENTAL
MONITORING REPORT
Rocky Flats Plant
JANUARY - DECEMBER 1972
DOW CHEMICAL U.S.A.
/
Rocky Flats Division
U.S. ATOMIC ENERGY COMMISSION CONTRACT AT(29-1)-1106
Health Physics Research & Ecology
-------
-------
107
Printed RFP-ENV-72
April 13, 1973
ANNUAL ENVIRONMENTAL MONITORING REPORT
ROCKY FLATS PLANT
January through December 1972
Including Estimates of Releases to the Environment
from Plant Operations
Merlyn R. Boss, Parrel D. Hobbs, Robert W. Loser,
and Donald E. Michels
DOW CHEMICAL U.S.A.
ROCKY FLATS DIVISION
P. O. BOX 888
GOLDEN, COLORADO 80401
Prepared under Contract AT(29-1)-1106
for the
Albuquerque Operations Office
U. S. Atomic Energy Commission
-------
08
RFP-ENV-72
CONTENTS
Introduction 1
Summary 1
Monitoring Data Collection, Analysis, and Evaluation 2
Applicable Standards 2
Airborne Effluent Monitoring 2
Ambient Air Surveillance Monitoring Programs 2
High Volume Air Sample Network 3
Waterborne Effluent Monitoring 4
Regional Water Monitoring Program 4
Vegetation Sampling Program 5
Soil Sampling Program 5
References 5
Tables 1 through 16 7
Figures 1 through 6 27
-------
i09
RFP-ENV-72
ANNUAL ENVIRONMENTAL MONITORING REPORT
ROCKY FLATS PLANT
January through December 1972
Merlyn R. Boss, Parrel D. Hobbs, Robert W. Loser, and Donald E. Michels
INTRODUCTION
The Rocky Flats Plant is owned by the U.S.
Government and operated by Dow Chemical U.S.A.
under contract with the U.S. Atomic Energy
Commission. The plant is located in Jefferson
County, Colorado, about 16 miles northwest of
Denver (Figure 1).
The site consists of about 2,520 acres of fenced
property. At the approximate center of the site is
the controlled area consisting of 384 acres, in which
the production and manufacturing buildings are
located.
The Rocky Flats Plant is primarily a radioactive
metal fabrication and chemical processing plant,
consisting of foundries, fabrication shops,
chemical recovery and purification operations,
together with associated support functions.
Annual precipitation recorded at the site during
1972 was 14.78 inches, with a record of 24.67
inches during 1969. The extreme temperatures
recorded during 1972 were —12° to 96°F, with an
annual mean temperature of 69° F. The mean wind
velocity was 7.7 miles per hour, with a peak gust
of 105 miles per hour on January 11, 1972. The
predominant wind direction during 1972 was from
the northwest, and occurred during 21 percent of
the hourly observations. Peak gust wind velocities
in excess of 50 miles per hour occurred monthly,
except during late summer and early fall.
The area is nearly devoid of trees. Assorted low-
growing prairie grasses, prickly pear, yucca or
Spanish bayonet cactus, constitute the main
ground cover.
Surface water runoff from the Rocky Flats Plant
is from west to east. Runoff is carried from the
property by two major drainage basins; the North
and South forks of Walnut Creek on the north,
and Woman Creek lying to the south. South Walnut
Creek is considered to be the main effluent water
course. The confluence of North and South Walnut
Creeks lies just east of the government property
(see Figure 2). East of the confluence is Great
Western Reservoir. Woman Creek flows east from
the government property and into Mower Reservoir,
then into Standley Lake. North Walnut Creek,
South Walnut Creek, and Woman Creek are con-
sidered to be effluent-release routes and have been
designated A, B, and C, respectively.
The environmental monitoring program at the
Rocky Flats Plant is the responsibility of the
Environmental Control group of the Research and
Ecology Division. The information and data
contained in this report were released monthly to
the Rocky Flats Area Office of the U S. Atomic
Energy Commission, the Division of Occupational
and Radiological Health of the Colorado Depart-
ment of Health, and the Regional Office of the
Environmental Protection Agency. The Colorado
Department of Health also maintains air-, soil-,
and water-sampling programs around the Rocky
Flats site as a portion of their statewide surveillance.
SUMMARY
Results of the environmental monitoring program
in the vicinity of the Rocky Flats Plant during
1972 indicate that yearly average environmental
concentrations of plutonium in air and water was
less than 2 percent of applicable Federal
Standards. Total long-lived alpha emitter concen-
trations in air, including natural background, was
less than 30% of the soluble plutonium-239
standard. No apparent changes were noted in the
distribution of plutonium in soil from previous
years. Changes in the distribution isopleths
compared with 1971 are a result of additional
sample results in the computer modeling program
and do not reflect physical movement of plu-
tonium in soils.
-------
no
RFP-ENV-72
MONITORING DATA COLLECTION,
ANALYSIS, AND EVALUATION
Applicable Standards
The numerical guides governing the release of
radioactive effluent materials and the concentration
standards for radioactivity in environmental samples
are those found in AECMC-0524.1 Although the
standards for radioactivity relate to concentrations
above background, all measurements reported
herein include background radioactivity.
All radioactive isotopes in plant effluents and
environmental samples are assumed to be soluble
for purposes of comparison with the appropriate
concentration standards. The assumption con-
cerning solubility is an additional safeguard since
the Maximum Permissible Concentration (MFC)
guidelines for soluble radioisotopes are more
restrictive than those for insoluble radioactive
materials. Concentrations of total long-lived alpha
activity in airborne effluents from the plutonium
areas are maintained below 0.06 X 10~12 /nCi/ml,
the soluble plutonium-239 concentration standard
set for an individual in an uncontrolled area.
Airborne effluents from the uranium areas are
maintained below 0.3 X 10"12 /uCi/ml. The con-
centration of uranium plus plutonium in effluent
water is maintained below 1667 X 10~9 /jCi/m),
the soluble plutonium-239 concentration standard
set for a suitable sample of an exposed population.
The comparable standard for americium-241 is
1333 X 10~9 jiCi/ml. The standards given in
AECMC-OS24 indicate that soluble plutonium-239
concentrations to a maximum of 5000 X 10~9 MCi/m
are permissible in water at the boundary of the
controlled area.
The Environmental Protection Agency's proposed
standard for beryllium as defined in Subpart C of
40CFR Part 61 requires that total emissions be less
than 10 grams in a 24-hour period.2
Effluent waters containing chemical contaminants
from plant operations are controlled so that
they will meet the receiving water standards of
the Colorado Department of Health3 combined
water-use classifications ABj -CD] for a potable
drinking water supply, cold water fishery, water
for industrial uses, and water for irrigation.
Airborne Effluent Monitoring
Primary control of airborne radioactive and non-
radioactive effluents is exercised at the discharge
stacks. All effluent exhaust systems are isokinetically
sampled on a continuous basis. Each release point
is provided with at least two effluent sampling
stations in all plutonium facilities. Effluent air
samples from the plutonium and uranium buildings
are analyzed by direct counting for total alpha
activity. Effluent beryllium concentrations from
the appropriate buildings are determined using the
atomic absorption method.4 Minimum Detectable
Concentration (MDC) for effluent samples from
the plutonium areas is <0.002 X 10~12 /iCi/ml.
The effluent MDC from the uranium areas is
<0.001 X 10'12 juCi/ml, while the MDC for a
typical beryllium effluent sample is <0.0002 ng/m3.
Table 1 shows the quanitites of total long-lived
alpha emitters and beryllium released from the
plutonium, uranium, and beryllium production
areas. The total releases shown in Table 1 also
include long-lived alpha activity due to natural
background.
Ambient Air Surveillance Monitoring Programs
Ambient air monitoring of filterable airborne
particulates containing long-lived alpha and beta
emitters is conducted continuously at the plant.
The sampling network within the controlled area
presently consists of 12 air samplers, five of which
are located at the perimeter fence (see Figure 3).
The samples arc collected daily on Whatman 41
filter media.
The sampling pumps (Cast, Model 0465-V4A-025)
operate at an average sampling rate of 2 cfm. All
samples are analyzed daily by direct radiometric
counting and then allowed to decay for seven days
priorjo determining the long-lived alpha activity.
Although Rocky Flats Plant operations release only
trace amounts of beta-emitting radionuclides, the
samples which are collected on Friday of each week
are also analyzed for long-lived beta emitters
-------
following a seven-day decay. These data comprise
part of the U.S. Atomic Energy Commission
fallout monitoring network as well as providing
radiological background information.
Air samplers operating at 2 cfm are operated for
10 minutes out of each hour in the surrounding
communities of Boulder, Broomfield, Denver,
Golden, Lafayette, Marshall, and Westminster
(see Figure 4). Other 2-cfm samplers are operated
continuously at the mouth of Coal Creek Canyon
(S-l 1, three miles west-southwest of the site) and
Wagner (S-l 8, 2.5 miles southeast of the site).
The air samples are collected on Whatman 41 filter
paper and are analyzed weekly. Then they are
allowed to decay for seven days before determining
the long-lived alpha and beta concentrations.
The MDC for long-lived alpha activity in community
samples collected ten minutes of each hour is typically
<0.0045 X 10~12 AiCi/ml. The continuously opera-
ting community sample MDC is <0.0008 X lO'12
/uCi/ml. Sample MDC's for long-lived alpha activity
from the controlled area range between <0.0055 X
10~12 MCi/ml for a daily sample to <0.0018 X 10~12
/uCi/ml for a sample collected over the weekend.
Typical MDC's for a long-lived beta activity in
samples taken within the controlled area of the
Rocky Flats Plant are <0.0629 X 10'12 fid/ml,
whereas the community sample MDC's are about
<0.0513 X 10~12 /jCi/ml. The monthly average
concentrations of long-lived alpha emitters from the
various communities are shown in Table 2 together
with the corresponding concentrations from the
sampling network located within the controlled area
of the Rocky Flats Plant. The yearly summary in
Table 2 shows the average concentration, in all
samples collected from the communities surrounding
the Rocky Flats Plant, to be <0.0048 ± 13% X 10'12
juCi/ml.*
"Throughout the data presented, samples whose concentrations
wtre below the MDC are assumed to be the MDC for averaging
purposes. The minimum and maximum concentrations at each
location are shown, together with the uncertainties in the analysis
due to counting error at the 95 percent (2a) confidence level.
The error term associated with the average concentration at each
location represents the deviation (at the 95 percent confidence
level) of the mean of the sample concentrations observed.
Ill
RFP-ENV-72
Table 3 shows the average monthly long-lived
beta concentrations for the surrounding communities
and the Rocky Flats site. The average beta concen-
tration in air samples from the surrounding commu-
nities (including natural background) is
<0.1078 ±21% X 1(T12
High Volume Air Sample Network
In February 1971, a network of 12 continuously
operating high volume air samplers were installed at
approximately two to four miles radially from the
Government property (locations S-26 through S-37,
shown in Figure 4). The samples are collected daily
on Whatman 41 filter paper at an average flow rate
of 20-25 cfm. The daily filters are composited into
weekly samples, whose total volumes vary between
3,000 - 6,000 m3, depending upon the condition
of the sampling pump. These sample filters are
radiochemically analyzed specifically for plutonium
following isolation on an ion-exchange column.5
The chemical plutonium recovery for individually
composited samples is determined (internally
yielded) by adding a known quantity of plutonium-
236 tracer and quantified by means of alpha pulse
height analysis. One-half of the daily sample filters
are retained in order to provide a check on
anomalous air concentrations. Typical MDC's
for plutonium range down to <0.01 X 10~15 /iCi/ml
for a 5,000 m3 sample.
Weekly results for individual stations have been
reported on a monthly basis to the U.S. Atomic
Energy Commission, the United States Environ-
mental Protection Agency, and the Colorado
Department of Health. The stations comprise a
statistically homogeneous group,* as indicated in
Table 4. Furthermore, the data for individual
stations also comprised homogeneous sub-groups
in all cases but one.** Since all stations are
statistically homogeneous, their data can be
combined. For each week of sampling, the analyses
i.e., CaVE ±2o =c ±tf
L.avg ±/0 = c ±IQ 975V Hd_£^L
c~ is volume weighted whenever the volume is measured.
n is the number of samples.
"Log-normal statistics are used in the numerical analysis of data
from these stations.'
**Station S-34 yielded four samples that were anomalously large
compared to the remaining samples. However, the truncated
group of 46 samples yields the lowest geometric standard
deviation (GSD) observed (Table 4), suggesting that the four
high samples should be regarded as part of the background
distribution.
-------
112
RFP-ENV-72
were averaged. Values are shown in Figure 5 and
listed in Table 5. The year-long geometric average
plutonium concentration is 0.000044 pCi/ml X 10~12
multiplied or divided by 1.33.* For purposes of
comparison with earlier results, the volume-weighted
monthly arithmetic station averages for the high-
volume air sampler network are shown in Table 5-A.
Waterborne Effluent Monitoring
Daily effluent water samples are collected from the
outfalls of Ponds A, B-4, and C (Figure 2). The
daily samples are analyzed for pH, nitrates,
phosphates, fluorides, and hexavalent chromium.
BOD5 and dissolved oxygen are determined in
Pond B-4 three days each week.5
These daily samples are composited into weekly
samples for analysis of combined uranium and
plutonium (gross alpha) and specifically for
plutonium. The weekly samples from Pond B-4
also are analyzed specifically for americium. The
combined alpha activity from uranium and plu-
tonium are isolated from other long-lived alpha
emitters using an ion-exchange technique.5
All effluent water samples are internally yielded
for plutonium using a plutonium-236 tracer.
Samples analyzed for americium are internally
yielded using a curium-244 tracer. The uranium,
plutonium, and americium alpha activities are
determined from pulse-height analysis of the
samples. The minimum detectable sample con-
centration for uranium, plutonium, and americium
in water is <0.01 X 10'9 /nCi/ml.
The weekly composite samples are further com-
posited into monthly samples in which the con-
centrations of 42 different elements are determined.
These analyses are performed using emission and
atomic absorption spectrometry. Monthly
composite samples are combined quarterly and
analyzed by standard methods7 for the various
nonradioactive constituents shown in Table 6.
"Uncertainty in mean value is commonly expressed as a plus or
minus value. Denotation of uncertainty takes a different form
when log-normal statistics are used. The term 0.000044
multiplied or divided by 1.33 means that the limits of un-
certainty on the mean value 0.000044 are given by
0.000044 X 1.33 and 0.000044-h 1.33. In this case, and in all
other tables and graphs in this section, the factors for
uncertainty pertain to 95 percent confidence levels.
Radioactive concentrations in the holding ponds
from which samples were collected are shown in
Tables 7,8,9, and 10. The annual average con-
centrations of plutonium-239 in Ponds A, B-4, and
Cwere<1.68 X 10'9 nCi/ml, 14.86 X 10'9 /iCi/ml,
and <1.33 X 1CT9 pCi/ml, respectively. The
americium-241 concentration in Pond B-4 averaged
<2.15 X 10~9 juCi/ml. The estimated total releases
of the radionuclides processed at the Rocky Flats
Plant and released in effluents from Pond B-4
are also shown in Tables 8 and 10. The yearly
average concentration in samples collected from
Pond B-4 have been volume weighted, since the
flow rate is measured at the outfall from this pond.
Flow rate measurements from Pond B-4 were
supplied, since June, by the Denver Office of the
U.S. Geological Survey when construction at this
location forced the closure of the sampling and
volume measurement station. Flow rates through
Ponds A and C are not presently measured.
Daily water samples also are collected from Walnut
Creek at Indiana Street, upstream from Great
Western Reservoir, for weekly compositing.
Radioactive analysis on these samples is identical to
those of Pond B-4. The results of these samples are
shown in Table 11. The annual average plutonium-
239 and americium-241 concentrations at this
location were 8.82 X 10~9 piCi/ml and <1.01 X 10'-
/iCi/ml respectively.
Regional Water Monitoring Program
Semimonthly water samples are collected from four
reservoirs and nine tap water locations around the
Rocky Flats and greater Denver areas. The
reservoirs include: (1) Baseline, whose primary use
is a source of irrigation water, (2) Ralston Reservoir,
the water supply for portions of Denver, Arvada,
Wheatridgc, and the Rocky Flats Plant, (3) Great
Western Reservoir, which is the Broomfield water
supply, and (4) Standley Lake, which serves
Westminster and portions of the Thornton-
Northglenn area (see Figure 4). Tap or treated
water is collected from the surrounding communities
of Arvada, Boulder, Broomfield, Denver, Golden,
Lafayette, Louisville, Thornton, and Westminster.
These data are summarized in Table 12 and include
background radioactivity. The annual average
plutonium-239 concentration in all reservoirs was
-------
'9
in
<0.48 X 10'9 juCi/ml and <0.31 X 10
all treated water samples. Analysis for americium is
routinely performed on water samples from Great
Western and Standley Reservoirs. These data
are presented in Table 1 3. The annual average
americium-241 concentration in all reservoirs was
<0.29 X 10'9 juCi/ml.
Twice each year - normally in June and September -
water samples are collected from additional surround-
ing reservoirs, lakes, and streams. Samples are
collected out to a distance of about 20 miles from
the plant and are analyzed for gross alpha (combined
uranium and plutonium) and specifically for
plutonium. These data are presented in Table 14
and include background radioactivity. The annual
average plutonium-239 concentration in all
reservoirs was <0.32 X 10~9 /jCi/ml. Samples from
locations greater than five miles are felt to be un-
influenced by the plant, and are therefore used as
indicators of environmental background levels in
water. The MDC for both gross alpha and plu-
tonium in these samples is <0.01 X 10~9 juCi/ml.
Vegetation Sampling Program
Vegetation samples are collected twice yearly from
about 40 locations onsite and more than 50
locations outside of the government property.
These collections are normally made in June and
September each year and are taken over an area
of approximately 315 square miles around the
plant.
113
RFP-ENV-72
Soil Sampling Program
Soil samples from uncontrolled property covering a
75 square mile area are collected twice yearly.
Samples are routinely collected in June and
September from 60 locations lying on the circum-
ferences of three circles having radii of 1, 2, and
5 miles, centered at the plant site. Soil from the
top five centimeters is normally collected for
plutonium analysis.
The samples are oven dried at 120°C and weighed,
homogenized, and sieved to remove the coarser
rubble. Ten grams of pulverized soil are prepared
for analysis using the method reported by Talvitie.8
All samples are internally yielded using a plutonium-
236 tracer, and the plutonium content is deter-
mined by alpha pulse-height analysis. The minimum
detectable concentration for plutonium-239 in these
samples is <0.03 X 10"6 /uCi/g (dry weight).
The results of the soil sampling program are shown
in Table 16. Isopleths of plutonium concentrations
have been derived by computer analysis of over
300 individual sample results, and are presented in
Figure 6. No apparent changes in analytical results
were noted from previous years soil analysis.9
Contour changes appearing in Figure 6 are a result
of additional sample results in the computer
modeling program and do not reflect movement of
plutonium in soil.
The samples are collected from alongside public
rights-of-way and consist primarily of native
grasses and volunteer feed grain crops. The root
systems of these plants arc not collected. The
resultant samples are radiochemically analyzed,
unwashed, for total plutonium content. All
vegetation samples are internally yielded using
plutonium-236 and the plutonium content is
determined by alpha pulse-height analysis.5
The MDC for plutonium-239 in these samples is
<0.01 X 10"9 /^Ci/g (dry weight). A summary of
these data is shown in Table 1 5. The annual
average concentration of plutonium-239 in
vegetation samples was <0.33 X 10"6 juCi/gram
(dry).
REFERENCES
1. Standards for Radiation Protection, U.S. Atomic Energy
Commission, AEC Manual, Chapter 0524, 1968.
2. National Emission Standards for Hazardous Air Pollutants,
40CFR Part 61, Subpart C (Proposed), U.S. Environ-
mental Protection Agency, 1971.
3. Water Quality Standards and Stream Classification,
Water Pollution Control Commission, Colorado Depart-
ment of Public Health, 1971.
4. D. L. Bokowski, Rapid Determination of Beryllium by a
Direct-Reading Atomic Absorption Spectrometer, Am,
Ind. Hyg. Assoc., 29, p. 474-481 (1968).
-------
114
RFP-ENV-72
5. Standard Laboratory Procedures for the Determination 1. Standard Methods for the Examination of Water and
of Radioactivity and Chemical Concentrations in • Wastewater, 1 3th Edition, American Public Health
Environmental and Bioassay Samples, D. L. Bokowsfci, Association, New York, 1971.
(ed), RFP-2039, to be published.
SNA. Talvitie, Anal Chem., Vol. 43. No. 13, p 1827-1830
(1971)
6. R. I. Larsen, A Mathematical Model for Relating Air
Quality Measurements to Air Quality Standards: USEPA, 9. L. M. Steward and M. R. Boss, Annual Report:
Air Programs Pub. AP-89, Supt. of Doc., Washington, Environmental Safeguard '71, RFP-ENV-71B, March 10,
1971. 1972.
-------
U5
RFP-ENV-72
TABLES
The values presented herein are composites of many thousands of individual
analytical results. Where appropriate, concentration averages which are weighted
by volume or weighted by the number of samples are so indicated.
Small discrepancies may result between calculations attempted by the reader and
the published results because of these weighting or rounding techniques.
Table 1. Airborne Effluents Released to Atmosphere During 1972.
Sample Period
Jan
Feb
Mar
Apr
May
Jun
Total"
Jul
Aug
Sept
Oct
Nov
Dec
Total"
Plutonium Areas
(MCQ*
< 1.4
< 4.3
< 2.0
< 2.4
< 3.0
< 2.9
< 1.8
<16
< 3.3
< 4.4
< 4.1
<12
<42
Measured as Total Long-Lived Alpha Emitters
Enriched Uranium Areas Depleted Uranium Areas
< .39
< .63
< .92
<1.4
< .79
< .95
< .50
< .46
< .55
< .42
< .89
< .75
<3.6
< 1.9
< 2.5
*< 1.9
< 8.2
< 2.8
< 5.0
<22
< 3.4
< 2.4
< 4.2
< 5.2
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116
RFP-ENV-72
Table 2. Total Long-Lived Alpha Concentrations ±2a (X 10"1J ^Ci/ml) In Air.
Community
Jan
Feb
Volume Weighted Averages
Mar
Apr
May
Jun
Boulder
Broomfield
Coal Creek
Denver
Golden
Lafayette
Marshall
Wagner
Westminster
Community
Average
Rocky Mats
Plant Average
<0 0066
<0.0068
<0 0039
<0 0047
<0.0043
<0.0036
<0.0047
<0.0051
<0.0049
<0.0048
<0 0052
± 47%
±612%
± 56%
± 51%
± 37%
± 58%
± 81%
±131%
± 55%
±58%
± 15%
<0.0106
<0.0160
<0 0054
<0 0070
<0.0061
<0 0063
<0.0079
<0 0036
<0 0070
<0.0070
<0 0053
±109%
± 77%
± 64%
± 79%
±118%
± 61%
±138%
± 0%
± 53%
± 29%
± 9%
<0.0024 ±
<0.0098 ±
<0 0056 ±
<0.0054 ±
<0.0051 ±
<0.0066 ±
<0.00(.2 ±
<0.0043 ±
-------
Table 2. Total Long-Lived Alpha Concentrations ±2a (X 10~la /iCi/ml) in Air (continued).
117
RFP-ENV-72
Community
Boulder
Broomfield
Coal Creek
Denver
Golden
Lafayette
Marshall
Wagner
Westminster
Community
Summary
Average
Rocky Flats Plant
Summary
Average
26
22
26
14
25
24
26
25
16
204
1501
Vol(m')
3451.7
5190.4
5642.9
2040.5
3040.2
2689.9
2559.2
3394.2
1672.0
29681.0
180604.0
July—December 1972 — Summary
Cone. (X 10"12
<0.0008
<0.0014
i/ml)
_* *
<0.0023
<0.0010
<0.0008
<0.0013
<0.0011
<0.0019
<0.0026
<0.0019
<0.0018
0.0086 ±26%
0.0226 ±23%
0.0125 ±22%
0.0121 ±27%
0.0114 ±27%
0.0163 ±20%
0.0116 ±24%
0.01 13 ±24%
0.0131 ±20%
<0.0049±17%
<0.0034±39%
<0.0026±55%
<0.0047 ±55%
<0.0041 ±31%
•C0.0055 ±27%
<0.0060 ±15%
<0.0040 ±24%
<0.0054±32%
0.0226 ±23%
0.1699 ±
<0.0042 ±14%
<0.0063±22%
%of
Standard*
<2S.O
<17.0
<13.0
<23.5
<20.5
<28.0
<30.0
<20.0
<27.0
<21.0
<10.5
•The standard for Pu-239 in air is 0.02 X 10"
controlled area of the Rocky Flats plant.
** Volume weighted average.
AiCi/ml for community samples and 0.06 X 10"'a /jCi/ml for samples taken within the
Community
Boulder
Broomfield
Coal Creek
Denver
Golden
Lafayette
Marshall
Wagner
Westminster
Community
Summary
Average
Rocky Flats Plant
Summary
Average
50
46
51
39
50
49
51
47
39
422
2982
1972 Summary — Total Long-Lived Alpha Activity in Air
Cone. (X 10'" MCi/ml)
Vol(m3)
6414.1
7146.5
8116.0
4448.8
5460.8
5093.2
4986.5
6086.6
3914.0
51749.5
355473.0
Cmin
<0.0014
<0.0010
<0.0008
<0.0013
<0.0011
<0.0019
<0.0026
<0.0019
<0.0018
Cmax "a
0.0693 ±35%
0.0491 ±23%
0.0125 ±22%
0.0142 ±21%
0.0139 ±21%
0.0163 ±20%
0.0159 ±28%
0.0113 ±24%
0.0183 ±20%
Ca*v*g±2o
<0.0049 ±65%
<0.0042 ±71%
<0.0034 ±26%
<0.0056±21%
<0.0047 ±17%
<0.0057 ±18%
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118
RFP-ENV-72
Table 3. Total Long-Lived Beta Activity in Air (X 10~"
Community
Jan
Feb
Volume Weighted Averages
Mar Apr
May
Jun
Boulder <0.4384 ±266%
Broomfield <0.2000 ±335%
Coal Creek 0.3076 ±363%
Denver <0.2462 ±263%
Golden <0. 1713 ±271%
Lafayette 0.41 55 ±274%
Marshall <0.1834 ±256%
Wagner <0.0461 ±184%
Westminster 0.3445 ±373%
Community
Average <0.2613± 60%
Rocky Flats
Average <1.0964 ± 42%
<0.1381 ±195%
<0.2384 ± 68%
<0.0611 ± 66%
<0.0889 1 88%
<0.1010 ± 25%
<0.0847 ±151%
<0.1200 ±155%
•C0.0439 ± 75%
<0.0834 ± 75%
<0.0938± 37%
<0.0944 ± 1 8%
<0.0468±698% <0. 1054 ±586%
<0.1073 ± 96% <0.1016± 91%
<0.1033 ± 89% <0.1075 ± 88%
<0. 11541 83% <0.2581 ± 62%
<0.0632 ± 34% <0. 3055 ±110%
<0.0894± 80% <0. 1247 ±153%
<0.0657 ±116% <0.1081 ± 57%
<0.0406 ± 6% <0. 1776 ±430%
<0.1253±167% <0. 1280 ±345%
<0.0766± 38% <0. 15811 48%
<0.0739 ± 16% <0.4512± 36%
<0.2211 ±113%
<0.1401 ±128%
<0.0705 ± 57%
<0.2259 ±179%
<0.2464 ± 46%
<0.1739 ±226%
<0.21S1 ±129%
<0.0563 ±209%
<0.3798 ±346%
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RFP-ENV-72
Tabli 3. Total Long-Lived Beta Activity in Air (X 10"" fid/ml) (continued).
Community
Boulder
Broo infield
Coal Creek
Denver
Golden
Lafayette
Marshall
Wagner
Westminster
Community
Summary
Average
Rocky Flats Plant
Summary
Average
26
22
26
14
25
24
26
25
16
204
Vol(m3)
29681.0
July-December 1972 - Summwy
Cone. (X 1Q-" MCi/ml)
^min
<0.0356
<0,0203
<0.0090
<0.0090
<0.0130
<0.0213
<0.0532
•C0.0319
<0.0207
Cmax **»
0.1815 i 9%
0.3365111%
0.1312 ±11%
0.1763±12%
0.2650 t 8%
0.2746 ± 8%
0.2827 ± 9%
0.1943± 8%
0.3722 ±11%
CaVg ±2o
<0.0912 ± 74%
<0.0569 ±172%
<0.0437±1I2%
<0.0658 ±109%
<0.0830 ± 92%
<0.0846 ± 78%
<0.1022± 76%
<0.0731 ± 79%
<0.0917±133%
<0.0090
<0.0629
0.3722 ±11%
2.048S± 3%
<0.0719 ± 32%
<0.1118± 12%
<0.22
•The standard is 33 X 10~" tiCi/ml for total long-lived beta activity in air for community samples and 100 X 10'" MCi/ml for samples taken
within the controlled area of the Rocky Flats plant.
••Volume weighted average.
1972 Summary - Total Long-Lived Beta Activity in Air
Conc.JX 10'
Community
Boulder
Broomfield
Coal Creek
Denver
Golden
Lafayette
Marshall
Wagner
Westminster
Community
Summary
Average
Rocky Flats Plant
Summary
Average
50
46
51
39
50
49
51
47
39
422
572
Vol(m3)
6414.1
7146.5
8116.0
4448.8
5460.8
5093.2
4986.5
6086.6
3873.5
51749.5
46292.0
<0.0207
<0.0203
<0.0090
<0.0090
<0.0130
<0.0213
<0.0384
<0.0319
<0.0207
<0.0090
<0.0626
1.5317 ±4%
0.6623 ±3%
1.2028 ±4%
0.8613 ±5%
0.6630 ±5%
1.4903 ±4%
0.6261 ±6%
0 6701 ±4%
0.9906 ±4%
1.5317 ±4%
7.1393±1%
±2a
<0.1259 ±75%
<0 0794 ±90%
<0.0739 ±75%
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p
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121
RFP-ENV-72
Table 4. Plutonium Concentrations in Offtite Air Samplai, 1972
Avwagts.
Sampler ^g** °g No. of Samples Max. Min. Date
S-26 .066 X -
S-27 .052 X -
S-28 .040 X -
S-29 .043 X -
S-30 -.033 X-
S-31 .049 X -
S-32 .064 X -
S-33 .065 X -
S-34 .060 X -
S-35 .049 X -
-
-
'
-
-
-
-
.
S-36 .031 X T-
S-37 .039 X +
.3 2.9 51 .84
-------
122
RFP-ENV-72
Table 5-A. Offsitt Plutonium Concentration in Air i2o (X 10"" uCi/ml).
Location
Jan
Feb
Volume Weighted Averages
Mar Apr
May
S-26
S-27
S-28
S-29
S-30
S-31
S-32
S-33
S-34
S-35
S-36
S-37
Average
Location
S-26
S-27
S-28
S-29
S-30
S-31
S-32
S-33
S-34
S-35
S-36
S-37
Summary
Average
•The soluble
0.34± 141%
<0.09 ±1270%
-
0.39 ± 113%
-
<0.18 ± 106%
0.31 ± 129%
0.25 ± 28%
<1.77 ± 239%
<0.36± 192%
<0.03 ± -
-
0.49 ± 78%
n
26
24
22
26
22
25
25
25
25
26
22
21
289
plutonium standard is
0.36 ± 94%
<0.19 ±105%
<0.13±123%
<0.97 ±267%
<0.07 ±200%
0.73 ±130%
<0.47 ±202%
0.40 ±100%
<0.08 ±112%
0.30 ±120%
0.20 ±160%
0.18 ± 78%
<0.34± 53%
Ja
Vol(m')
133743
73605
1 32444
101743
80734
98288
103343
93564
96673
85359
117374
95031
1211901
20 X 10"" MCl/ml to
<0.22 ±105%
<0.11 ±100%
<0.21 ± 95%
<0.19 ±179%
<0.21 ±143%
<0.23±126%
<0.20±135%
<0.11 ±227%
0.22 ±100%
0.16± 62%
<0.11 ±173%
<0.44± 70%
<0.20 ± 15%
nuary-June 1972 -
Cmin
<0.01
<0.02
<0.01
<0.02
<0.02
<0.02
<0.02
<0.02
<0.01
<0.02
<0.01
<0.02
<0.01
a population group.
<0.06±133%
<0.11 ±218%
<0.05 ± 80%
<0.14±136%
<0.10 ±100%
<0.04 ±100%
<0.08 ±100%
<0.04 ±125%
<0.06±117%
<0.10 ±150%
<0.05 ±140%
<0.04 ±100%
<0.07 ± 14%
Summary
Cone. (X V0"'! uCi/ml)
Cmax±2a
0.84 ±8%
0.38 ±9%
1.50 ±4%
3.37 ±3%
0.59 ±6%
1.30 ±4%
1.34 ±4%
0.81 ±8%
5.74 ±4%
0.99 ±5%
0.47 ±8%
0.65 ±4%
5. 74 ±4%
<0.04 ±200%
<0.09 ± 897o
<0.06 ±117%
<0.06±133%
<0.07 ±1437o
<0.12 ±158%
0.20 ±140%
<0.10 ± 80%
<0.07 ±171%
<0 03 ± 67%
<0.04 ±125%
<0.07 ±100%
<0 07 ± 14%
Cavg ±2a
<0 17 ± 51%
<0.1 1 ± 41%
<0.16 ± 86%
<0.33 ± 79%
<0.11 ± 52%
<0.29 ± 54%
<0.24 ± 49%
<0.17 ± 46%
<0.42 ±121%
<0 19 ± 50%
<0.08 ± 69%
<0.12 ± 52%
<0.20 ± 27%
Volume Weighted Averages i
Location
S-26
S-27
S-28
S-29
S-30
S-31
S-32
S-33
S-34
S-35
S-36
S-37
Average
Jul
<0.01 ± 0%
<0.04 ±375%
<0.01 ± 0%
<0.05 ± 80%
<0.03 ± 67%
<0.05 ± 80%
<0.06±183%
<0.08 ±325%
<0.07 ±114%
<0.09 ± 89%
„
<0.06 ± 83%
<0.04 ± 25%
Aug
<0.09 ± 56%
<0.08 ±688%
<0.05 ±100%
-------
123
RFP-ENV-72
Table 5-A. Offsite Plutonium Concentration in Air ±2o (X 1(T" MCi/ml) (continued).
Location
S-26
S-27
S-28
S-29
S-30
S-31
S-32
S-33
S-34
S-35
S-36
S-37
Summary
Average
293
July—December 1972 — Summary
Cone. (X IP'15 MCi/ml)
n
26
26
26
26
25
23
25
25
25
24
16
26
Vol(m')
105248
72102
149944
58218
92901
.81548
48551
88385
63543
64835
92204
77090
^rnin
<0.01
•C0.01
<0.01
<0.02
<0.01
-------
124
RFP-ENV-72
Table 6. Nonradioactive Materials Released in Effluent Water, Annual Averages.
Sampling Point
Parameter
A. Physical and Biological
Color (Pt-Co units)
Turbidity - JT U
Total Dissolved Solids - mg/1
BOD, - mg/1
B. Chemical
Sulfate (as SO4) - mg/1
Chloride - mg/1
Chromium (Cr*6 as Na,CrO,)Mg/l
Cyanide - mg/1
Fluoride — mg/1
Arsenic (total) Mg/'
Barium (total) Mg/1
Beryllium (total) Mg/1
Cadmium (total) Mg/1
Copper (total) Mg/1
Iron (total) Mg/1
Lead (total) Mg/1
Manganese (total) Mg/1
Selenium (total) Mg/1
Silver (total) Mg/1
Zinc (total) Mg/I
Phenols Mg/1
Surfactants mg/1
Nitrate (as NOj) mg/1
1 Total solids.
*The Colorado Water Pollution Control Commission also requires an 8
and disinfection.
fUnits are for drinking water. They do not apply to discharge water.
A
15
0.7
319.'
NA
33.5
28.
< 5.
< 0.01
0.87
< 5.5
<100.
< 1.5
< 1.0
18.
25.
9.3
9.2
< 7.3
< 1.0
34.
< 3.5
< 0.02
35.2
B-4
25
0.8
387.'
< 8.7
76.5
57.
< 5.
< 0.01
0.71
< 6.5
<100.
< 1.3
< 1.0
27.
30.
9.5
5.5
< 8.0
< 1.0
49.
< 5.0
0.5
3.5
C
13
0.6
193.'
NA
37.0
12.
< 5.
< 0.01
0.59
< 6.0
<100.
< 1.8
< 1.0
15.
23.
9.3
6.4
< 6.7
< 1.0
53.
< 3.5
< 0.03
0.5
Standard
15 Units
5 Units
500.
30.'
250.
250.
50.
O.Olf
l.Ot
10.0
1000.
lO.f
1000.
300.
SO.f
SO.f
10.
50.
5000.t
1-t
O.Sf
45.t
Agency
USPHS
USPHS
CDH
CDH
USPHS
USPHS
USPHS
USPHS
USPHS
USPHS
USPHS
USPHS
USPHS
USPHS
USPHS
USPHS
USPHS
USPHS
USPHS
USPHS
USPHS
USPHS
> BODS reduction for facilities having secondary treatment
-------
125
RFP-ENV-72
Table 7. Radioactivity in Pond (A) Water Samples.
U + Pu
Cone. (X 10"° uCi/ml)
Pu
Cone. (X 10"' yCi/ml)
Jan
Feb
Mar
Apr
May
June
Summary
Average
n
3
4
5
4
5
4
25
Cmm t2° cmax "o
4.92
9.01
3.90
5.06
0.94
3.60
0.94
± 9%
± 6%
t 9%
t 8%
±20%
+-11%
±20%
8.85 ±
12.84 +
16 35 ±
7.94 +
6%
5%
5%
6%
3.29 ±10%
4.36 ±
16.35 ±
9%
5%
CavR ±2o
7.15 +
10.30 ±
10.29 ±
6.74 ±
2.23 +
4.07 +-
6.74 ±
70%
28%
54%
33%
47%
14%
23%
*-min
0.13
0.29
0.17
0.13
0.10
0.47
0.10
±2o
±55%
±35%
±47%
±53%
±65%
±30%
±65%
Cmax "o
0.71 ±20%
3.15 ±10%
9.92 ± 6%
0.41 ±30%
0.43 ±35%
0.92 ±20%
9.92 ± 6%
' CaVg ±20
0.35 ±219%
1.17 ±181%
2. 66 ±192%
0.32 ± 64%
0.24 ± 85%
0.73 ± 45%
0.98 ± 83%
July
Aug
Sept
Oct
Nov
Dec
Summary
Average
1972 Summary
1972 Average
%of Standard*
4
5
4
3
3
4
23
48
4.68 ± 9%
2.74 ±11%
3.43 + 6%
5.64 ± 5%
7.68 + 4%
5.96 ± 4%
2.74 +11%
0.94 ±20%
6.84 +
13.53 ±
19.92 +.
19.50 +
24.16 +
28.62 +
28.62 +
28.62 +
7%
5%
3%
3%
3%
2%
2%
2%
6.02
7.40
8.89
10.75
13.29
14.69
9.89
8.17
<0.16(
± 27%
* 75%
+ 136%
±176%
+ 176%
±112%
± 31%
± 19%
%
0.37
0.42
0.34
0.73
<0.01
<0.01
<0.01
<0.01
±30%
±30%
±20%
±14%
+
± -
± —
+ —
2.02 ±
6.17 ±
17.61 ±
8.80 +
1.81 +
2.21 ±
17.61 ±
17.61 ±
13%
8%
3%
3%
8%
8%
3%
3%
1.07 +107%
3.03 ±104%
4.82 ±281%
4.00 ±264%
<0.61 ±422%
<0.93 ±189%
<2.4S ± 70%
<1.68 ± 54%
<0.10%
•The U -I- Pu soluble standard is
cPu
RCGij RCGpu
The soluble plutonium standard is 1667 X 10~* uCi/
**Sample weighted average.
<1 Where: RCGij = 10,000 X 10"' nCi/ml
RCGPu = 1667 X 10-' MCi/ml
-------
126
RFP-ENV-72
Table 8. Radioactivity in Pond (B-41 Effluent Water Samples.
Jan
Feb
Mat
Apr
May
Jun
Summary
Average
Jul
Aug
Sept
Oct
Nov
Dec
Summary
Average
1972 Summary
1972 Average
% of Standard*
n
4
4
5
4
5
4
26
4
5
4
1
4
4
22
48
Vol
(10' liters)
17.722
48.831
50.412
55.530
46.035
65.350
283.880
29.232
24.121
31 463
18 839
29.356
20968
153.979
437.859
,
U + Pu
Cone. (X 10-' nCi/ml)
Crnm*2" Cmax±2o Cavg12a
8.75 1 6%
17.63± 5%
1 1 .59 1 5%
9.00 1 6%
4.50 1 9%
3.06 1 9%
3.061 9%
4.64 110%
2.44 112%
2.80 ± 8%
(1)
57.27 1 2%
45.24 ± 2%
2.44 112%
2.44112%
33.54 ±3%
38.2713%
31.1213%
25.3314%
20.41 ±4%
10.3414%
38.27 13%
10.7314%
8.47 16%
20.52 12%
(1)
74.52 11%
134.83 ±1%
1 34.83 ±1%
134.8311%
17.33 ±104%
26.841
21.281
14.88 1
10.74 t
6.46 ±
16.241
7.73 1
5.541
51%
54%
79%
71%
75%
24%
66%
70%
9.641126%
28.85
67.20 1
88.66 1
36.54 1
25.29 1
1 .00%
17%
66%
81%
31%
Release
(mCi)
0.307
1.311
1.073
0.826
0.494
0.422
4.433
0.226
0.134
0.303
0.543
1.973
1.859
5.038
9.471
Pu
Cone. (X 10-' MCi/ml)
cmin ±2°
1.06120%
1.79 ±19%
2.48114%
1.42 117%
0.85 122%
0.66 125%
0.66125%
1.131 6%
0.48130%
0.68114%
(1)
34.831 1%
29.67 1 2%
0.48 ±30%
0.48 130%
Cmax *2°
5.18 1 2%
8.14 1 7%
3.44 111%
16.11 * 6%
8.97 1 6%
4.56 110%
16.11 1 6%
5 29 1 9%
6 94 1 8%
15.37 i 3%
(1)
64.781 1%
123.62 1 1%
123 62 i 1%
123.62 1 1%
Cavg 12
-------
Table9. Radioactivity in Pond (C) Water Samples.
U + Pu
Cone. (X 10
Jan
Feb
Mar
Apr
May
J un
Summary
Average
Jul
Aug
Sept
Oct
Nov
Dec
Summary
Average
1972 Summary
1972 Average
%of Standard*
3
3
5
4
5
4
24
4
5
4
3
3
4
23
47
•The soluble U + Pu standard is
Cmln±2a
4.37 ±10%
10.52 ± 6%
5.69 ± 8%
3.85 ±10%
1.57 ±15%
2.01 ±16%
1.57 ±15%
2.71 ±12%
301 ±10%
2.10 + 8%
5.66 ± 5%
2.06 ± 7%
2.98 + 6%
2.06 ± 7%
1.57 ±15%
cmax ±2°
7.77 ± 7%
• 14.41 ± 5%
14.93+ 5%
8.83 ± 5%
7.87 ± 7%
2.97 ±11%
14.93 ± 5%
5.14 ± 9%
14.61 ± 6%
15.24 ± 3%
8.57 ± 4%
26.20 + 2%
15.59 ± 3%
26.20 ± 2%
26.20 + 2%
— 0.68 ± 32%
1.52 ± 68%
2.50 ± 78%
3.48 ±270%
3.15 ± I 1%
<1 24 ±230%
<0.38 ±186%
<2.0S ± 54%
<1.33 ± 42%
0.08%
RCGij RCGpu
= 10,000 X 10~' MCi/ml
RCGPu = 1667 X 10"' MCi/ml
The soluble plutonium standard is 1667 X 10 ' MCi/ml.
'•Sample Weighted Average.
Table 10. Americium Released in Effluent Water from Pond B-4.
Jan
Feb
Mar
Apr
May
Jun
Summary
Average
Jul
Aug
Sept
Oct
Nov
Dec
Summary
Average
1972 Summary
1972 Average
% of Standard*
n
4
4
5
6
5
5
29
4
4
4
1
3
4 ,
20
49
Cmin ±2°
0.13
<0.01
0.22
0.56
0.11
0.34
<0.01
<0.01
<0.01
0.16
<0.01
3.82
15.20
<0.01
<0.01
Cone. (X 10'' uCi/ml)
Cmax ±2°
0.81
1.62
1.32
2.80
1.86
2.51
2.80
2.69
1.69
1.23
<0.01
12.94
15.38
15.38
»
15.38
Cavg1 2o
0.53 ± 90%
<0.79 +132%
0.55 ±100%
1.28 + 73%
' 0.62+142%
0.88 ±131%
<0.80 ± 34%
<0.88 +223%
<0.79 ±151%
0.74 ±101%
<0.01 ±-
8.31 ±136%
11.90 ± 61%
<4.11 ± 62%
<2.15 ± 51%
<0.07%of Std.
Total Release
(mCi)
0.009
<0.039
0.028
0.071
0.029
O.OS7
<0.227
<0.026
<0.019
0.023
<0.0002
0.244
0 249
<0.632
<0.941
•The soluble americium concentration standard is 1333 X 10"'
"Volume weighted average (volumes from Table 8).
-------
RFP-ENV-J2
THIS PAGE INTENTIONALLY LEFT BLANK
-------
129
RFP-ENV-72
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-------
130
RFP-ENV-72
Table 12. Summary of Radioactivity in Reservoir and Tap Water Sources.
January-June 1972 - Summary
U + Pu
Cone. (X 10"' uCi/i
Reservoir
Baseline
Great Western
Ralston
Standley
Summary
Average
n
3
12
12
12
39
cm!n ±2"
0.58 ±5%
2.59 ±2%
3.64±1%
2.93 ±1%
0.58 ±5%
Cmax ±2°
1.45 ±3%
8.B1 ±1%
25.77 ±1%
7.23 ±1%
25.77 ±1%
nl)
0.95 ±118%
4.32 ± 29%
10.22 ± 43%
5.22 ± 54%
6.15 ± 28%
%of
Standard*
0.01
0.06
0.13
0.07
0.08
Pu
Cone. (X 10"' uCi/ml)
Cmin ±2"
<0.01 1 -
0.08 ±13%
0.03 ±18%
0.04 ±17%
<0.01 ± -
Cmax ±2"
0.13 ±11%
1.161 4%
1.86 ± 2%
0.73 ± 5%
1.86 1 2%
CJ'V'E ±20
<0.07 ±2 1 3%
0.28 ± 71%
0.52 ±118%
0.28 ± 50%
<0.34± 50%
%of
Standard'
<0.01
0.02
0.03
0.02
<0.02
Tap Water Source
Arvada
Boulder
Broomfield
Denver
Golden
Lafayette
Louisville
Thornton
Westminster
Summary
Average
1 Suspect Data.
*Th» cnlllMo
12
12
12
12
12
12
12
11
11
106
0.70 ±5%
0.53 ±5%
1.36 ±2%
0.38 ±6%
0.57 ±6%
0.53 ±5%
0.73 ±4%
3.95 ±2%
0.66 ±4%
0.38 ±6%
. Significantly high
ITJ- Pii
6.33 ±1%
2.78 ±3%
5.03 ±1%
13.68 ±1%
(30.30 ±1%)'
8.02 ±1%
5.24 ±1%
39.87 ±1%
5.11 ±1%
39.87 ±1%
value compared to
cu cpu
2.39 ± 50%
1.56± 43%
3.02 ± 28%
5.22 ± 52%
5.67 ± 96%
1.87 ± 73%
1.94 1 52%
14.52 1 58%
2.11 ± 41%
4.18 ± 28%
0.04
<0.03
0.05
0.08
<0.09
<0.04
0.04
<0.17
0.03
<0.06
<0.01 ±-
<0.01 ± -
0.08 ±11%
0.04 ± 4%
<0.01 ± -
<0.01 ± -
0.10 ±31%
<0.01 ± -
<0.01 ± -
<0.01 ± -
1.61 ± 3%
1.25 ± 4%
0.81 ± 3%
4.29 1 2%
3.07 ± 2%
2.10 ± 3%
1.91 ± 3%
2.10 ± 4%
0.58 ± 4%
4.29 ± 2%
<0.35 ± 87%
<0.28 ± 77%
0.32 ± 50%
0.63 ±125%
<0.59 ± 94%
<0.37 ± 97%
0.38 ± 80%
<0.42 ± 92%
<0.27 ± 39%
<0.40 ±28%
<0.02
<0.02
<0.02
0.04
<0.04
<0.02
0.02
<0.03
<0.02
<0.02
average and previous year values.
1 Where;
Rrr.Ti —
in nno X io~' u<
1i/ml
The soluble plutonium standard is 1667 X 10"' uCi/ml.
**Sample weighted average.
July—December 1972 — Summary
*
U + Pu
Cone. (X 10"' uCi/ml)
Reservoir
Baseline
Great Western
Ralston
Standley
Summary
Average
n
11
11
11
9
42
Cmin ±2o
<0.01 ± -
1.11 ±3%
0.94 ±3%
2.52 ±1%
<0.01 ±-
Cmax *2o
18.69 ±1%
9.25 ±1%
12.15 ±1%
7.47 ±1%
18.69 ±1%
Ca*vg "o
<4.62 ±102%
4.2 6 ± 44%
4.37 ± 58%
4.14± 36%
<4.36± 31%
%of
Standard*
<0.07
<0.10
0.06
0.06
•C0.07
Pu
Cone. (X 10"' uCi/ml)
Cmin "0
-------
Table 12. Summary of Radioactivity in Reservoir and Tap Water Sources (continued).
1972 Summary
U + Pu
Cone. (X JO'' MCi/mJ)
Reservoir
Baseline
Great Western
Ralston
Standley
Summary
Average
n
!•»
23
23
21
81
Cmin «o
<0.01 ± -
1.11 ±2%
0.94 ±2%
2.52 ±1%
0.0) ±-
Cmax ±2°
18.69 ±1%
9.25 ±1%
25.77 ±1%
7.47 +1%
25.77 ±1%
Cav* ±2a
<3.83 ±96%
4.29 ±23%
7.43 ±36%
4.76 ±33%
<5.22 ±21%
%of
Standard*
<0.06
<0.08
<0.10
0.06
<0.08
Pu
131
RFP-ENV-72
Cone. (X 10~' ^Ci/ml)
Cmin *2o
<0.01 ± -
<0.01 ± -
<0.01 ± -
<0.01 ± -
<0.01 ± -
Cmax ««
2.22 ±3%
6.42 ±1%
1.86 ±2%
0.95 ±4%
6.42 ±1%
Ca*vJ ±2o
<0.44 ±87%
<0.67 ±88%
<0.44 ±71%
<0.34±40%
<0.48 ±39%
%of
Standard*
<0.03
<0.04
<0.03
<0.02
' <0.03
Tap Water Source
Arvada
Boulder
Broomfield
Denver
Golden
Lafayette
Louisville
Thornton
Westminster
Summary
Average
1 Suspect data.
•The soluble
23
23
23
22
23
22
23
20
22
20!
<0.01 * -
<0.01 ± -
<0.01 ± -
0.38 ±6%
0.24 ±5%
0.26 ±5%
0.53 ±6%
1.05 ±3%
0.66 ±4%
<0.01 ± -
6.33 ±1%
2.78 ±3%
7.13 ±2%
13.68 ±1%
(30.30 ±1%)'
8.02 ±1%
6.44 ±1%
39.87 ±1%
7.43 ±1%
39.87 ±1%
<1.81 ±37%
<1.40 ±29%
<2.67 ±29%
3.92 ±39%
4.04 ±66%
1.43 ±50%
1.97 ±37%
10.25 ±48%
2.14 ±36%
<3.20 ±21%
<0.04
<0.03
<0.05
0.07
0.06
<0.04
<0.04
<0.14
0.04
<0.05
<0.01 ± ~
<0.01 ± -
<0.01 ± -
<0.01 ± -
<0.01 ± -
<0.01 ± -
<0.01 ± -
<0.01 ± -
<0.01 ± -
<0.01 ± -
1.61 ±3%
1.25 ±4%
2.85 ±3%
4.29 ±2%
3.07 ±2%
2.73 ±3%
1 91 ±3%
3.04 ±1%
2.09 ±3%
4.29 ±2%
<0.38 ±52%
<0.37 ±47%
<0.46 ±61%
<0.62 ±67%
<0.48 ±61%
<0.48 ±62%
<0.36±59%
<0.66±60%
<0.45 ±52%
<0.31 ±21%
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132
RFP-ENV-72
Table 13. Americium Concentrations in Reservoir Water Samples.
January to June 1972
Cone. (X 10"' MCi/ml)
July to December 1972
Cone. (X 10"' MCi/ml)
Reservoir n
Great Western 9
Standley 7
Summary 16
Average
Reservoir
Great Western
Standley
Summary
Average
Cmin
<0.03
<0.01
<0.01
n
18
12
30
•The soluble americium standard is 1 333 X
**Sample weighted average.
Cmax Cavg ±2o n Cm|n Cmax
1.23 0.36± 95% 9 <0.01 1.43
0.42 <0.12±112% 5 <0.01 0.78
1.23 14 <0.01 1.43
<0.255 ± 74%
Americium Concentrations in Reservoirs — 1972
Cone. (X 10"' MCi/ml)
cmm Cmax Cavg ±2o
<0.01 1.43 <0.38±59%
<0.01 0.78 <0.16±92%
<0.01 1.43
<0.29 ±50%
10"' MCi/ml.
Cavg ±2o
<0.40 ±
<0.218±
<0.334 ±
%of Standa
<0.028
<0.012
<0.022
94%
191%
75%
,rd«
Table 14. Radioactivity in Surrounding Lakes, Reservoirs, and Streams.
June 1972
U + Pu Cone. (X 10"' MCi/ml)
PuConc. (X 10"' MCi/ml)
Location
<5 Miles
> 5 Miles
Summary
Average
n Cmin ±2o
U ' 1.18 ±3%
14 0.60 ±5%
25 0.60 ±5%
Cmax "o
6.90 ±1%
99.84 ±1%
99.84±1%
CaVg ±2o
3.34 ± 42%
14.62 ±108%
9.66 ± 89%
cmin ±2o
<0.01 ± -
<0.01 ± -
<0.01 ± -
Cmax ±2"
1.17 ±4%
0.27 ±5%
1.17 ±4%
Ca*v*g±2(J
<0.24 ±91%
<0.08 ±64%
<0.15 ±64%
September 1972
U + Pu Cone. (X 10"' MCi/ml)
Location
<5 Miles
>S Miles
Summary
Average
" Cmin ±20
15 0.32 ±7%
16 0.16±9%
31 0.16 ±9%
Cmax ±2o
11.65 ±1%
79.22 ±1%
79.22 ±1%
Ca*v'g±2o
2.25 ±72%
15.20 ±82%
8.93 ±74%
Cmin ±2"
<0.01 ± -
<0.01 ± -
•C0.01 ±-
Pu Cone. (X 10"' MCi/ml)
Cmax ±2"
6.33 ±2%
1.25 ±3%
6.33 ±2%
CaVg ±2o
<0.54 ±165%
<0 37 ± 52%
<0.45 ±91%
Summary 1972
Location
S Miles
Summary
Average
*Th» eslllth
U + PuConc. (X 10"'
" cmin ±20 Cmax ±2o
26 0.32 17% 11.65 ±1%
30 0.1 6 ±9% 99^84 ±1%
56 0.16 ±9% 99.84 ±1%
1. ctantlnrH fnr , mivtnr* nf II 4- Pu i
MCi/ml)
Cavg ±20
2.71 ±40%
14.93 ±62%
9.26 ±55%
Cu CPu
%of
Standard
<0.05
<0.16
.
<0.11
. £1 Whpr,
Pu Cone. (X 10"' MCi/ml)
Cmin ±2o Cma
<0.01 ± - 6.33
<0.01 ± - 1.25
<0.01±- 6.33
r- Rrr.n — in.or
x ±20 Ca*v*g ±20
±2% <0.41 ±120%
±3% <0.24 ± 48%
±2%
<0.32 ± 72%
IO X 10"' uCi/ml
%of
Standard
<0.03
<0.01
<0.02
RCGjj RCGpu
The soluble plutonium standard is 1667 X 10"' MCi/ml.
Sample weighted average.
RCGpu = 1667 X 10"
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133
RFP-ENV-72
Table 15. Plutonium in Vegetation Samples.
Location
89
Location
<1 Mile
1-5 Miles
> S Miles
Summary
Average
*Sample weighted average.
June 1972
Pu Cone. [X 10~* AiCi/g(dry)]
September 1972
Pu Cone. |X 10"' >iCi/g(dry) |
n
40
29
20
Cmin ±2°
<0.01 ± -
<0.01 i -
<0.01 ± -
Cmax ±2°
3.11 ±3%
1.23 ±4%
1.05 ±4%
Ca*vg±2a
<0.39 ±55%
<0.12 ±92%
<0.22 ±66%
n
58
47
21
Cmin ±2<7
0.05 ±14%
0.03 ±12%
0.02 ±13%
cmax ±2°
4.14 ±8%
2.71 ±3%
1.04 ±9%
Cavg ±2a
0.48 ±34%
0.31 ±44%
0.20 ±50%
<0.01 4 -
3.11 ±4%
126
0.02 ±12%
4.14 ±8%
<0.26±41%
1972 Summary
Pu Cone. (X 10'' >iCi/g(dry)|
n
98
76
41
215
Cmin ±2
-------
34
RFP-ENV-72
THIS PAGE INTENTIONALLY LEFT BLANK
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135
RFP-ENV-72
,,t Boulder
m pop. 66.780
D
Lakewood
pop. 93,000
Figure 1. Rocky Flats Area.
Figure 2. Liquid Effluent Water Courses.
A- DRAINAGE
NORTH WALNUT CREEK
GREAT WESTERN RESERVOIR
B'3 SOUTH WALNUT CREEK
B-DRAINAGE
SEWAGE AND
WASTE
TREATMENT
C-DRAINAGE WOMAN CREEK
Not to scale.
27
-------
33S
RFP-ENV-72
Not to scale.
Figure 3. Rocky Flats Onsite Air Samplers.
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137
RFP-ENV-72
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138
RFP-ENV-72
.001 p
.0005 -
x
in
O
5
1
.0001
.00005
Note: Values less than .00004 are biased high.
They are dominated by analyses that were
below the detection limit.
.00001
20 25 30
1972 (weeks)
40 45
50
Figure 5. Weekly Average Plutonium Concentrations in Air, Offsite Geometric Average Concentrations for 12 Stations.
(S-26 through S-37)
30
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139
RFP-ENV-72
u
^
i
,c
VI
.O
c
a.
•8
_
a
8
-------
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141
EVALUATION OF DOSE TO THE PUBLIC NEAR ROCKY FLATS
Addendum to the Rocky Flats 1972 Environmental Monitoring Report
RFP-ENV-72
April 13, 1973
I. Introduction:
Rocky Flats releases uranium and plutonium radionuclides through effluent air and water. The
effluents are carefully monitored at the point of release and at the plant boundary. In addition,
measurements are made of air and drinking water at points of consumption by the general public.
II. Summary
»
The concentrations of uranium and plutonium in public areas as a result of air and water effluent
releases from the Rocky Flats Plant are all below one percent of the relevant AECM 0524
Radioactivity Concentration Guides (RCG).
111. Monitoring Data and Analysis
a. Water
Bimonthly water samples are collected from nine tap water locations around the Rocky Flats
areas. These locations include Arvada, Boulder, Broomfield, Denver, Golden, Lafayette, Louisville,
Thornton and Westminster. Following is the annual average plutonium and plutonium-plus-
uranium concentrations for these locations and a comparison with the applicable standard. The
standard for uranium is 10,000 X 10~9 pCi/ml and for plutonium-239 is 1667 X 10'9 /aCi/ml. The
standard for soluble uranium plus plutonium is
1
Tap Water Samples.
Arvada
Houltler
Bronmfteld
Denver
r.okh'it
Lafayette
Louisville
Thornton
Westminster
Average
^U +
U + Pu
Avg. Cone.
(X I0~' MCi/ml)
<1.81 ±37%
,<1.40 ±29%
<2.67 ±29%
3.92 ±39%
4.04 ±66%
1.43 ±50%
1.97 ±37%
10.25 ±48%
2.14 ±36%
<3.20 ±21%
*~Pu ^
RCGpu
% of KCG
<0.04
<0.03
-------
142
b. Air is sampled continuously at twelve Ideations around the plant at distances between two and four
miles. The samples are collected daily on Whatman 41 filter paper at an average flow rate of
20-25 cfm. The daily filters are composited into weekly samples, whose volumes vary between
3000 and 6000 m3, and are radiochemically analyzed specifically for plutonium. These stations
sample the air to which the general public in the vicinity of the plant might be exposed. The major
population centers are at a greater distance (10 to 20 miles) and therefore are exposed to a lower
plutonium concentration in air from any Rocky Flats contribution because of greater dilution.
Log-normal statistics are used in the numerical analysis of the data from these stations. Following
is a summary of the annual average plutonium concentrations at these locations and a comparison
with the Radioactivity Concentration Guide.
The RCG used is for soluble plutonium-239 in air and is 20 X 10"IS jiCi/ml. The use of the soluble
plutonium RCG adds additional conservatism to the interpretation since the plutonium is probably
in an insoluble form for which the RCG is 330 X 10'15
Air Samples.
Direction from Center Avg. Pu Cone.
Sampler of Plant (X 10"" MCi/ml) % of RCG
S-26 W 0.066 0.33
S-27 W O.OS2 0.26
S-28 NW 0.040 0.20
S-29 NW 0.043 0.22
S-30 N 0.033 0.17
S-31 NE 0.049 0.25
S-32 E 0.064 0.32
S-.13 E 0.065 0.33
S-34 SE 0.060 0.30
8-35 S 0.049 0.2S
5-36 S 0.031 0.16
S-37 SW 0.039 0.20
Average 0.044 0.22
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PREVIOUSLY PUBI 'CLY RELEASED
143
RFP-ENV-73
April 26, 1974
ANNUAL ENVIRONMENTAL
MONITORING REPORT
Rocky Flats Plant
JANUARY - DECEMBER 1973
A^u/v
mr^
DOW CHEMICAL U.S.A.
Rocky Flats Division
U.S. ATOMIC ENERGY COMMISSION CONTRACT AT(29-1)-1106
Environmental Sciences & Waste Control
-------
-------
Printed RPP^ENV-73
April 26, 1974
ANNUAL ENVIRONMENTAL MONITORING REPORT
ROCKY FLATS PLANT
A USAEC-Owned Facility
January through December 1973
Environmental Control
George J. Werkema, Group Leader
Environmental Sciences and Waste Control
Milton A. Thompson, Director
CONTRIBUTORS
I. B.Allen
D. C. Coonfield
R. R. Gunning
F. D. Hobbs
C. T. Illsley
J. M. West
DOW CHEMICAL U.S.A.
Rocky Flats Division
P. 0. Box 888
Golden, Colorado 80401
Prepared under Contract AT( 29-1) -1106
for the
Albuquerque Operations Office
U. S. Atomic Energy Commission
-------
146
RFP-ENV-73
DISTRIBUTION
INTERNAL
Library
R. W. Bistline
W. C. Bright
II. E. Bowman
R. V. Carroll (50 copies)
C. II. Dompierre
L. C. Farrell, Jr.
J. H. Hanes
R. D. Howertou (2 copies)
C. R. Lagerquist
R. D. Forest
J. B.Owen
M. A. Thompson (50 copies)
G. J. Werkema
J.F. Willging
Environmental Master File (2 copies)
EXTERNAL
USAEC Washington, D. C.
Major General Edward B. Ciller (5 copies)
USAEC-Germantown, Maryland
Gordon C. Facer
Blake P. Brown '
Dr. R. L. Walters
USAEC- New York, New York
Dr. John H. Harley
Dr. Herbert Volchok
Philip W. Krey
USAEC-Albuquerque, New Mexico
George Dennis
Harry D. Hawkins
Jack R Rocder (1 2 copies)
USAEC- Golden, Colorado
B. W. Colston (3 copies)
Savannah River Plant
C. M. Patterson
Sandia Corporation
Dr. W. H. Kmgsley
Lawrence Livermore Laboratory
Technical Information Department
Paul Guttikson
EXTERNAL (continued)
Los Alamos Scientific Laboratory
Flarry S. Jordan
Dr. L. J. Johnson
Mound Laboratory
Dr. D. G. Carfagno
Oak Ridge National Laboratory
Walter G. Stockdale (2 copies)
Union Carbide Corporation
K. Z. Morgan
Battelle Pacific N. W. Laboratories
R. C. Thompson
J.P.Corley
C. E. Elderkin
U. S. Public Health Service
Colorado Public Health Department
Dr. E. G. Dreyfus
A. J. Hazle
Robert D. Siek
B. S. Evans
Jefferson County (Colorado) Health Department
Don MacDougall (2 copies)
Boulder City-County Health Department
Dr. Charles H. Dowding, Jr.
City of Broomfield
G. D. DiCicro
V. C. Chancy
Environmental Protection Agency
James W. Shaw
Paul W. Smith (6 copies)
University of Colorado
Jerry Martin
Colorado State University
Dr. J. E. Johnson
Dr. F. Ward Whicker
U. S. Army Environmental Hygiene Agency
Commanding Officer
The Dow Chemical Company (Michigan)
C. E. Otis (5 copies)
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147
Kl'T-IiNV-73
CONTENTS
Introduction 1
Summary 2
Monitoring Data Collection, Analysis, and Evaluation 2
Applicable Standards 2
Airborne Effluent Monitoring 2
Data Reduction 3
Ambient Air Monitoring 3
Waterborne Effluent Monitoring 5
Regional Water Monitoring 6
Soil Sampling 6
Tritium 7
Sanitary Landfill 7
Assessment of the Rocky Flats Plant's Contribution to Public Radiation Dose ... 7
References 9
Tables 1 through 17 11
Figures 1 through 9 27
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148
RFP-ENV-73
THIS PAGE INTENTIONALLY LEFT BLANK
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349
RFP-ENV-73
ANNUAL ENVIRONMENTAL MONITORING REPORT
ROCKY FLATS PLANT
A USAEC-Owned Facility
January through December 1973
George J. Werkema and Milton A. Thompson
INTRODUCTION
The Rocky Flats Plant is owned by the U. S.
Government and operated by Dow Chemical U.S.A.
under contract with the U. S. Atomic Energy
Commission. The plant is located in Jefferson
County, Colorado, about 16 air miles northwest
of Denver (Figure 1).
The site consists of about 2,520 acres ot fenced
property. At the approximate center of the site is
a 384-acre, controlled area that contains all of the
Plant's major structures.
The Rocky Flats Plant is primarily a radioactive
metal fabrication and chemical processing plant.
It s mission involves foundry, fabrication, plutonium
recovery and purification operations, and associated
support functions.
Annual precipitation recorded at the site during
1973 was 21.55 inches. For the 21-year period,
1952 through 1973, the average annual rainfall was
15.84 inches. The extreme temperatures recorded
during 1973 were —7 to 97 °F, with an annual
mean temperature of 47 °F. The mean wind
velocity was 8.6 miles per hour, with a peak gust
of 92 miles per hour on January 1 2, 1973. Peak
gusts in excess of 50 miles per hour occurred
monthly, except during late s'ummer and early fall.
Hourly observations showed the predominant wind
direction during 1973 was from the west. This
direction accounted for 22% of wind-direction data.
Assorted low-growing prairie grasses, prickly pear,
and Spanish bayonet cactus constitute the main
ground cover. Cottonwood trees grow adjacent to
the watercourses.
Surface water runoff from the Rocky Flats Plant
is from west to east. Runoff is carried from Plant
property by two major drainage basins, the North
and South forks of Walnut Creek on the north, and
Woman Creek to the south. South Walnut Creek
is the main effluent watercourse. The confluence
of North and South Walnut Creek is one-half mile
east of the Plant's eastern boundary (Figure 2). One
mile east of the confluence is Great Western
Reservoir, the water supply for the city of Broom-
field. Woman Creek flows east from Rocky Flats
into Standley Lake or it can be diverted into
Mower Reservoir, a source of irrigation water.
Standley Lake is the water supply for the city of
Westminster and portions of the Thornton-
Northglenn area. North Walnut Creek, South
Walnut Creek, and Woman Creek are effluent
release routes and have been designated A, B, and
C, respectively.
The environmental monitoring program at the
Rocky Flats Plant is the responsibility of the
Environmental Sciences and Waste Control
Department's Environmental Control group. Most
of the information and data contained in this
report were released monthly to the Rocky Flats
Area Office of the U. S. Atomic Energy Commission,
the Division of Occupational and Radiological
Health of the Colorado Department of Health, and
the Regional Office of the Environmental Pro-
tection Agency. Concentrations of plutonium in
Rocky Flats and community ambient air and
airborne plutonium releases are presented for the
first time in this report.
-------
150
KFP-l-NV-73
The Colorado Department of Health also maintains
air, soil, and water sampling programs around t,he
Rocky Flats site as a portion of its statewide
surveillance. The Jefferson County Health Depart-
ment performs monthly sewage plant effluent
sampling and analysis and has a continuous
particulate air sampler on the plant site that is
operated by the Colorado Department of Health.
The Health and Safety Laboratory of the U. S.
Atomic Energy Commission maintains three
particulate air sampling stations in the vicinity of
the Rocky Flats Plant and periodically performs
soil sampling and analysis. Additional monitoring
is performed by the U. S. Environmental Pro-
tection Agency through its studies of accumulations
of plant effluent materials in various environmental
media.
SUMMARY
Results of the environmental monitoring program
in the Rocky Flats vicinity indicate the average
environmental concentrations of plutonium-239
in air and water during 1973 were less than two
percent of applicable U. S. Atomic Energy Com-
mission Radioactivity Concentration Guides.
Average concentrations of americium-241 and
hydrogen-3 (tritium) in water samples were less
than one percent of applicable U. S. Atomic Energy
Commission Radioactivity Concentration Guides.
The annual average concentrations of residual
chlorine, settleable solids, and turbidity in Rocky
Flats sewage plant effluent did not meet the new
wastewater discharge standards promulgated by the
Colorado Department of Health in 1973.
MONITORING DATA COLLECTION,
ANALYSIS, AND EVALUATION
Applicable Standards
The U. S. Atomic Energy Commission has published
radioactivity concentration guides (RCG's)1
governing concentrations of radionuclides in air
(RCGa) and water (RCGW) accessible for intake
by occupationally exposed individuals, incidentally
exposed individuals, and the population at large.
Although the standards for radioactivity relate to
concentrations above background, all measure-
ments reported herein include background radio-
activity. Numerical values of the standards are
cited as appropriate in the tables presented else-
where in this report.
All radionuclides in plant effluents and environ-
mental samples are assumed to be soluble for
purposes of comparison with appropriate concen-
tration standards. This assumption is an additional
safeguard since the radioactivity concentration
guides for soluble radionuclides are more restrictive
than those for insoluble radioactive materials.
During 1973, concentrations of total long-lived
alpha activity in airborne effluents from plutonium
areas were maintained below 60 X 10~15 micro-
curies per milliliter (MCi/ml), the soluble plutonium
concentration guide value for an individual in an
uncontrolled area. All references to plutonium
standards in this report pertain to plutonium-
239 unless otherwise noted.
Airborne effluents from uranium areas were main-
tained below 3 X 1CT12 juCi/ml during 1973. The
concentration of uranium plus plutonium in
effluent water at the plant boundary was main-
tained below 1600 X 10~9 /uCi/ml, the soluble
plutonium concentration guide value for a suitable
sample of an exposed population. The comparable
standard for americium-241 is 1300 X 10"9 MCi/ml.
The Environmental Protection Agency's discharge
limitation for beryllium is 10 grams in a 24-hour
period.2
Chemical and bacteriological parameters of effluent
water from plant operations arc compared with
waste water discharge standards promulgated by
the Colorado Department of Health,3 or by the
U. S. Environmental Protection Agency,4 which-
ever are more restrictive.
Airborne Effluent Monitoring
Exhaust air from Rocky Flats production and
research facilities was sampled continuously. In
the plutonium facilities, there were at least two
sampling points located in each exhaust air duct
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RFP
'-ErJV-73
downstream from the final stage of filters. Thp
filterable partieulate eomponent of the sample1'
stream was collected on Gelman Type E glass
fiber filter media. Partieulate samples were col-
lected weekly in uranium and beryllium facilities
and three times each week in plutonium facilities.
Each sample was analyzed for total long-lived alpha-
emitting radionuclides and beryllium, as appropriate.
Beginning in July 1973, samples from plutonium
facilities were composited weekly and analyzed
specifically for plutonium. All references to pluto-
nium concentrations in this report pertain to
plutonium-238, 239, and 240 unless otherwise noted.
Plutonium was determined in effluent and environ-
mental samples by a radiochemical technique in
which plutonium was separated from other radio-
nuclides by ion exchange chromatography,5
electroplated on a stainless steel disk, and analyzed
by alpha pulse height spectrometry. The chemical
recovery of that analytical procedure for plutonium
was determined by adding a standard aliquot of a
plutonium-236 tracer. Effluent beryllium concen-
trations were determined using the atomic absorption
method.6
The Minimum Detectable concentration (MDC)
for effluent samples from plutonium facilities was
0.002 X 10"12 MCi/ml by direct counting. The
effluent MDC from uranium facilities was 0.001
X 10~12 /zCi/ml by direct counting, and the MDC
for a beryllium effluent sample was 0.0002 Mg/m3.
Table 1 shows the quantities of radionuclides and
beryllium released from plant facilities during 1973.
The releases of total long-lived alpha-emitting
radionuclides shown in Table 1 include long-lived
alpha activity due to natural background.
Data Reduction
Throughout the data presented, samples that had
concentrations below the MDC were considered as
having the MDC for averaging'purposes. When one
or more MDC values are included in a set of values,
the computed mean value of that set is indicated by
a "less than" sign (<). The error term (±%)
associated with maximum concentrations (Cmax)
of total long lived alpha represents the counting
error at the 95 percent confidence level. The
average concentrations (C.1V(,) are represented by
pairs of numbers that define the 95% confidence
interval for C . This interval is centered at c
and is bounded oy the percentage deviations from c.
The probability that Cavf, lies within the stated
interval is 95%, or
c-t
0.975
— nc2
n(n-l)
avg
0.975
nc
n(n-l)
= 0.95,
where
c — is the arithmetic mean of observed
concentrations and is volume weighted
whenever the volume is measured,
tQ 975 - is taken from a standard t-test table,
n - is the number of samples, and
C — is an individual observed concentration.
Ambient Air Monitoring
Ambient air was sampled continuously at 13
locations within and on the perimeter of the Rocky
Flats Plant exclusion area (Figure 3). Cast, Model
0465-V4A-025 sampling pumps were used to draw
air through Gelman Type E glass fiber filter media
at a sampling rate of two cubic foot per minute
(cfm). The filters were collected five days each
week and analyzed for total long-lived alpha-emitting
radionuclides. The sample collected on Thursday
of each week was further analyzed for total long-
lived beta-emitting radionuclides. Beginning in
July 1973, the daily samples were composited
monthly and analyzed for plutonium. Sample
MDCs for long-lived alpha activity in the Plant's
exclusion area ranged between 0.0055 X 10~12
juCi/ml for a daily sample to 0.0018 X lO'12 AtCi/ml
for a sample collected over the weekend. The MDC
for long-lived beta activity in these samples was
typically 0.0629 X 10~12 /-iCi/ml.
-------
152
RFP-ENV-73
Table 1 shows the volume-weighted, monthly,
arithmetic, average concentrations of total long-
lived alpha-emitting radionuclides in airborne
particulates at sample stations within the Plant's
exclusion area during the first half of 1973. The
average concentration of total long-lived alpha-
emitters in ambient air at all exclusion area stations
during the first half of 1973 was<6.0 ±17% X 1CT15
MCi/ml. This concentration was less than 10%
of the RCGa for soluble plutonium in ambient air
accessible to incidentally exposed individuals.
Plutonium concentrations in ambient air within
the exclusion area during the last half of 1973
were obtained by radiochemical analysis of monthly
composite samples. The results are shown in
Table 3. The average concentration of plutonium
in ambient air at all exclusion area stations during
the last half of 1973 was <1.21 ±99% X 1(T15
MCi/ml. This concentration was less than 2% of
the RCGa for soluble plutonium in ambient air
accessible to incidentally exposed individuals.
The volume-weighted, monthly, arithmetic, average
concentrations of long-lived beta-emitting radio-
nuclides in airborne particulates of sample stations
within the exclusion area during 1973 are given in
Table 4. The annual, average concentration of
long-lived beta emitters at all exclusion area
stations during 1973" was <0.119 X 1(T12 MCi/ml.
This concentration was less than 0.12% of the
RCGa for total long-lived beta activity in ambient
air accessible to incidentally exposed individuals.
Airborne particulatc samples were collected at 12
locations surrounding the Rocky Flats Plant between
two and four miles distance from the plant center
(Figure 4). Air was drawn continuously through
Delbag Microsorban filter media at a 27 cfm
sampling rate. Beginning in April 1973, samples
were collected three days each week, composited
monthly, and radiochemically analyzed specifically
for plutonium. The MDC for plutonium in those
samples was 0.002 X 10"15 MCi/ml for a 30,000 m3
sample volume.
Table 5 shows the volume-weighted, monthly,
arithmetic, average concentrations of plutonium
in filterable airborne particlates at the two- to
four-mile sample stations. The annual, average
concentration of plutonium in ambient air at those
stations during 1973 was<0.053 ±53% X 10'1S
MCi/ml. That concentration was less than 0.26%
of the RCGa for soluble plutonium in public areas.
The monthly average concentrations of plutonium
at those stations are graphed in Figure 5.
Airborne particulate samples were collected at 9
locations in or near population centers in the
vicinity of the Rocky Flats Plant. Those locations,
shown in Figure 4, included Boulder, Broomfield,
Denver, Golden, Lafayette, Marshall, Westminster,
northwest Arvada (S-18), and Coal Creek Canyon
(S-l 1). Beginning in March 1973, air was drawn
continuously through Gelman Type E glass fiber
filter media at a sampling rate of 2 cfm. Prior to
March 1973, community ambient air was sampled
for 10 minutes each hour. Samples were collected
weekly and analyzed for total long-lived alpha- and
beta-emitting radionuclides. Beginning in July 1973,
weekly samples were composited monthly and
analyzed for plutonium. The MDC for long-lived
alpha activity in community samples was typically
0.0008 X 10~12 MCi/ml, whereas the total long-
lived beta activity MDC's were about 0.0094 X 10'12
MCi/ml. The MDC for plutonium in ambient
community samples was 0.015 X 10~1S MCi/ml for
a 3,000 m3 sample.
The monthly, volume-weighted, arithmetic, average
concentrations of long-lived alpha-emitting radio-
nuclides in ambient air at community samplers
during the first half of 1973 are shown in Table 6.
The average concentration of long-lived alpha
emitters during that period at all community
samplers was <2.6 ±20% X 10~ls MCi/ml. That
concentration was less than 13% of the RCGa for
soluble plutonium in public areas.
Monthly concentrations of plutonium at community
air sample stations during the last half of 1973 are
shown in Table 7. During that period, the average
concentration of plutonium in population centers
near the Rocky Flats Plant was <0.264 ±163%
X 10"1S MCi/ml. That concentration was less than
1.3% of the RCGa for soluble plutonium in public
areas. A single anomalous result from a sample
collected at Golden during July 1973 was responsible
for elevating the six-month average above typical
background concentrations for the area.
-------
RFP-ENV-73
The other six-month station averages shown in
Table 7 are typical of background from global
fallout.
Table 8 presents the monthly average concentrations
of long-lived beta-emitting radionuclidcs in ambient
air at community samplers during 1973. The annual.
average concentration of long-lived beta emitters
at all community samplers was <0.038± 14% X 10"12
juCi/ml. That concentration was less than 0.1%
of the RCGa for total long-lived beta activity in
public areas.
Waterborne Effluent Monitoring
Waste water discharged from the Rocky Flats Plant
consisted of treated sanitary and process waste,
cooling tower blowdown, steam condensatc, and
filter backwash from the water treatment plant.
Sanitary wastes were treated in an activated sludge,
secondary treatment facility, then discharged to
the "B" branch (southernmost) of Walnut Creek
(Figure 2). Four holding ponds. B-l, B-2, B-3, and
B-4 on the "B" branch of Walnut C'reek provided
additional treatment of water discharged from the
sanitary waste treatment facility. Ponds B-l and
B-2 were equipped t,o impound accidental spills.
The "A" branch of Walnut Creek received cooling
water blowdown and steam condensate from
process and laboratory facilities on the north side
of the plant reservation. Three holding ponds,
A-l, A-2, and A-3 were located on the "A" branch
of Walnut Creek, with A-l and A-2 being equipped
to impound accidental spills.
Water treatment plant filter backwash and cooling
tower blowdown from process facilities on the south
side of the plant reservation were discharged to
Woman Creek. One holding pond, C-l, was
located on Woman Creek and was usable for
impounding accidental spills.
Water was sampled continuously and collected
daily from the outfalls of Ponds A-3, B-4, and C-l
(Figure 2). The daily samples were composited
into weekly samples for analysis of uranium plus
plutonium (gross alpha) and specifically for
plutonium. Uranium and plutonium were isolated
!rom other long-lived alpha emitters by ion exchange
chromatography,5 and their concentrations deter-
mined by alpha pulse height spectrometry. Weekly
samples from Pond B-4 were also radiochemically
analyzed for americium. The chemical recovery of
the analytical procedure for plutonium was deter-
mined by adding a plutonium-236 tracer. Americium
recovery was determined by a curium-244 tracer.
The MDCs for uranium, plutonium, and americium
in water samples were identical and equal to
0.01 X 10'9 juCi/ml.
During 1973, sanitary waste was combined with
treated and low-level process waste for final treat-
ment at the sewage treatment plant. Annual,
average concentrations of chemical and biological
parameters of routine sewage plant effluent samples
are shown in Table 9 and compared with applicable
discharge water quality standards. The annual,
average concentrations of residual chlorine, settle-
able solids, and turbidity in the Rocky Flats sewage
plant effluent did not meet the new wastewater
discharge standards promulgated by the Colorado
Department of Health in 1973. A tertiary treatment
facility, which will be completed in 1974, will
remove solids and turbidity and permit more
efficient operation of the chlorine contact basin.
Concentrations of uranium plus plutonium, and
plutonium in water sampled at the outfalls of
Ponds A-3. B-4. and C-l are shown in Tables 10.
11, and 1 2, respectively. The annual, average
concentrations of plutonium in the outfalls of
Ponds A-3. B-4, and C-l during 1973 were
<0.29 ±37% X 10~9 MCi/ml «0.02% of RCGW)
7.37 ±47% X 10-'9 juCi/ml (0.46% of RCGW), and
<0.1 8 ±42% X 10~9 MCi/ml «0.01% of RCGW),
respectively. The monthly, average plutonium
concentrations in Pond B-4 are graphed in Figure 6.
The annual, average americium-241 concentration
in Pond B-4 effluent during 1973 was <1.79 ± 1 227*
X 10~9 /itCi/ml, as shown in Table 13. That con-
centration was less than 0.14% of the RCGW for
soluble amcriciurn-241 in public areas.
Walnut Creek was sampled continuously during
1973 at Indiana Street, which is downstream from
the confluence of the stream's five tributaries and
approximately one mile east of the Plant's east
boundary. A sample was collected daily; the
-------
154
RFP-ENV-73
samples were composited weekly and analyzed for
uranium plus plutonium, plutonium, and amer'icium.
Results of the analyses for uranium plus plutonium
and plutonium are shown in Table 14. The annual,
average concentrations of uranium plus plutonium
and plutonium at the Indiana Street location were
1 1.43 ±60% X 1(T9 AiCi/ml (0.27% of RCGW) and
3.1 1 ±43% X 10-9 /LiCi/ml (0.19% of RCGW),
respectively. The annual, average concentration of
americium-241 in Walnut Creek at Indiana Street
was<1.31 ±81% X 10'9 MCi/ml as shown in
Table 13. That concentration was less than 0.10%
of the RCGW for soluble americium-241 in public
water supplies.
In September 1973, water samples were collected
from additional area reservoirs, lakes, and streams.
Samples were collected to a distance of about 20
miles from the Plant and were analyzed for uranium
plus plutonium and specifically for plutonium.
The MDCs for uranium plus plutonium and pluto-
nium in those samples were identical and equal to
0.01 X I0~9 juCi/ml. The data presented in Table
16 show the annual, average plutonium concen-
tration in those samples was <0.31 ±0.76% X 10~9
MCi/ml. That concentration was less than 0.02%
of the RCGW for soluble plutonium in public
areas.
Regional Water Monitoring
Water samples were collected weekly from two
reservoirs and nine tap water locations around the
Rocky Flats and greater Denver areas. The reservoirs
included Great Western Reservoir, which is the
Broomfield water supply, and Standley Lake, which
served Westminster a"nd portions of the Thornton-
Northglcnn area (Figure 4). Tap or treated water
vas collected from the surrounding communities of
Arvada, Boulder, Broomfield, Denver, Golden,
Lafayette, Louisville. Thornton, and Westminster.
The weekly samples were composited monthly and
analyzed for uranium plus plutonium and plutonium.
These data are summarized in Table 15. The annual,
average plutonium concentration was <0.06 ±45%
X 10~9 MCi/ml in reservoir water samples and
<0.07 ±34% X 10~9 MCi/ml in community water
samples. These concentrations were less than
0 004% of the RCGW for soluble plutonium in
public water supplies. The concentration of
americium-241 was also determined in water
samples from Great Western Reservoir and Standley
Lake. Table 13 presents the results of those
analyses. The annual, average americium-241
concentrations in Great Western Reservoir and
Standley Lake were <0.16 ±148% X 10'9 MCi/ml
(0.01% of RCGw)and<0.20±185%X 10"9
MCi/ml «0.02% of RCGW), respectively.
Soil Sampling
The geometry of all soil samples is carefully con-
trolled by driving a 10-cm by 10-cm cutting tool
5 cm into undisturbed soil and excavating the soil
contained within the tool cavity. The samples are
oven dried at 120 °C, then weighed, homogenized,
and sieved to remove the coarser rubble. Ten grams
of pulverized soil are prepared for plutonium anal-
ysis using the method reported by Talvitie.7 The
chemical recovery of the analytical procedure for
plutonium is determined by adding a plutonium-236
tracer. The MDC for plutonium in these samples
is <0.03 X 10"6 MCi/g (dry weight). There are no
Federal standards for the concentration of plutonium
in soil.
Two land areas within the Rocky Flats Plant site
were studied extensively during 1973. An aerial
radiological survey of the site in 1973 indicated
maximum radiation levels about 5 times natural
background within a 1-hectare area southeast of
a former oil storage area, which is now covered
with asphalt. Soil samples collected by Dow Health
Physics personnel in 1970 and subsequent years
indicated the presence of plutonium in the soil in
the same area. The maximum concentration observed
in 1970 was 26 //Ci/m2. The 1970 soil analysis
data were published in a report by Michels.8
-------
RFP-ENV-73
Subsequent to the aerial survey, ground surveys of
the 1-hectare area, using sensitive field instruments
for detecting low-energy radiation (FIDLER), were
made by the USAEC Health and Safety Laboratory
and by Dow Environmental Control. An isorad
map from data provided by the Dow survey is
shown in Figure 7 Agreement between results of
the Health and Safety Laboiatory and Dow surveys
was good. Recent rudiochemica! analyses of a
limited number of soil samples from the area have
yielded plutonium concentrations up to 99.0
IdCi/m2. Those samples were taken from locations
indicated by the FIDLFR survey and were not
intended to correspond to previously sampled
locations.
In a second study, 200 soil samples were collected
at 50-foot intervals along five north-south traverses
between the Plant's security and boundary fences
to the east. The range of plutonium concentrations
in the soil from that area was 0.003 to 9.72 piCi/m2.
The samples were collected to determine the
sensitivity and calibration factor for an aerial
radiological survey by personnel from EG&G,
Incorporated.
Sixty routine soil samples were collected during
1973 in the plant environs. Samples were collected
each 1 8 degrees of drc on circles of 1-, 2-, and 5-
mile radius, concentric with the center of the plant,
and analyzed for plutonium. Compared to previous
years' data, the 1973 values for plutonium in soil
appeared significantly lower. This apparent
decrease was attributed to improved sensitivity and
reliability of the radiochemical method of analysis.
The 1973 data are displayed on an azimuthal map
in Figure 8. This map indicates the majority of
anomalous values were found in samples collected
in the eastern sector between N54°E and E54°S.
The distribution of plutonium in this sector is
related to the westerly, prevailing winds at Rocky
Flats.
Tritium
Tritium was released in plant effluent water during
1973 as the result of processing a shipment of
plutonium that, unknown to Rocky Flats Plant
personnel, had been contaminated with tritium by
another USAEO facility. To prevent a recurrence
of such an incident, procedures have been established
to detect tritium and other radionuclides in all
incoming shipments and in plant effluents. This
incident has been investigated by the USA EC9 and
by the USEPA.10
Beginning in October 1973, water sampled con-
tinuously at the outfalls of Ponds A-3, B-4, C-l,
and in Walnut Creek at Indiana Street was analy/ed
daily for tritium by liquid scintillation spectrometry
The water sample collected weekly at Great
Western Reservoir was also analyzed for tritium.
The average concentrations of tritium in those
samples are summarized in Table I 7.
Sanitary Landfill
The Rocky Flats Plant sanitary landfill is located at
the west end of an arroyo that collects surface
runoff water tributary to Walnut Creek. Except
during infrequent periods of high rainfall, the
"Landfill" branch of Walnut Creek is dry along
most of its length. Two earthen dams were con-
structed in the "Landfill" branch in September
1973 to retain landfill seepage water in which
concentrations of tritium above background were
detected. As the ponds filled, the water was
transferred to low-level, piocess-waste storage ponds.
Landfill seepage water has been analyzed daily
since October 1973 for tritium and other radio-
nuclides. The decrease in tritium concentration is
shown graphically in Figure 9.
ASSESSMENT OF THE ROCKY FLATS PLANT'S
CONTRIBUTION TO PUBLIC RADIATION DOSE
Throughout this report, it has been assumed that
plutonium discharged in Rocky Flats Plant effluents
is in a soluble chemical form. This assumption is
conservative because the RCGs for insoluble
plutonium in air and water are larger than those for
soluble plutonium.1 Radioactivity Concentration
Guides (formerly Maximum Permissible Concen-
trations) were originally recommended by the
International Commission on Radiological Pro-
tection (ICRP) "
-------
156
RFP-ENV-73
The ICRP selected bone as the critical organ for
uptake of soluble plutonium. The assumption, was
made that the residence time in any intermediate
organs, such as lung, the lymphatic system, or the
circulatory system, was relatively short for purposes
of long-term dose assessment. The ICRP derived
RCGs for radionuclides that localize in the bone
on the basis of a direct comparison with radium-226,
taking into account such individual differences
among radionuclides as radioactive decay, daughter
products, nonuniform distribution of radionuclides
in the bone, essentialness of exposed tissue, and
radioscnsitivity of exposed tissue.
The Radioactivity Concentration Guides for soluble
plutonium are those concentrations in air and
water that, after fifty years continuous exposure,
will result in a specific accumulation in the bone of
an exposed individual. That accumulation is the
amount of plutonium biologically equivalent to
0.003 ^Ci of radium-226 in exposure of the
population at large. The amount of plutonium
taken to be biologically equivalent to 0.003 ptCi
of radium-226 in the bone is 0.001 ^Ci. The 50-
year bone accumulations presented in the subsequent
discussion were calculated by multiplying 0.001 ^Ci
by the ratio of the observed concentration to the
RCG, that is,
C
Accumulation = 0.001 juCi X
avg
RCG
There is no direct means to compute radiation
dose commitments resulting from accumulation
of nonuniformly distributed alpha-emitting
radionuclides in bone. For purposes of uniformity
in reporting, population dose commitments in
this report have been estimated by multiplying
the ppropriate Radiation Protection Standard
by the ratio of the observed radionuclide con-
centration to the RCG, that is,
Dose = Standard X
avg
RCG
The Radiation Protection Standard for dose to the
bone for the population at large is 1 rem per year.
Air samplers are located on those public highways
nearest the Rocky Flats Plant boundary. The
plutonium concentrations in air samples collected
at those locations during 1973 are shown in Table 5.
The volume-weighted, annual, average concentration
of plutonium in air at those stations during 1973
was less than 0.053 X 10~15 pCi/ml. That con-
centration was less than 0.26% of the RCGa for
soluble plutonium in air accessible to the population
at large, and was indistinguishable from normal
fluctuations in plutonium concentration in air
from world-wide fallout. After 50 years of con-
tinuous exposure to air containing 0.053 X 10"15
juCi/ml plutonium, an exposed individual would
have a bone accumulation of 2.6 X 10~6 ^Ci of
plutonium and an annual dose commitment to the
bone of less than 2.6 X 10~3 rem.
Air samplers are located in population centers near
the Rocky Flats Plant. The plutonium concentration'
in air samples collected at those locations during
July-December 1973 are shown in Table 7. The
volume-weighted, six-month average concentration
of plutonium in air at those stations, including one
suspect result from the sample collected at Golden
in July, was less than 0.264 X 10~15 juCi/ml. This
concentration was less than 1.3% of the RCGa for
soluble plutonium in air accessible to the population
at large. After 50 years of continuous exposure to
air containing 0.264 X 10~15 /uCi/ml plutonium,
an exposed individual would have a bone accumula-
tion of 1 3 X 10~6 Ci of plutonium and an annual
dose commitment to the bone of less than
1.3 X 10~2 rem.
Samples of tap water from population centers near
the Rocky Flats Plant are collected weekly, com-
posited monthly, and analyzed for plutonium.
Results of analyses are shown in Table 15. The
sample-weighted, annual, average concentration of
plutonium in community water during 1973 was
less than 0.07 X 10~9 juCi/ml. This concentration
was less than 0.004% of the RCGW for soluble
-------
RFP-ETMV-73
plutonium in water accessible to the public at large.
After 50 years of drinking only water containing
0.07 X I0~9 juCi/ml plutonium. an exposed
individual would have a bone accumulation of
4 X 10~8 nC'i of plutonium, and an annual dose
commitment to the bone of less than 4 X 10~5
rem.
The critical organ for tritiatcd water exposure is
taken to be body tissue." Tritium equilibrates
rapidly with protium (hydrogen-l) atoms in body
tissue and fluids. An evaluation of dose can be
made by multiplying the radiation protection
standard, 0.17 rem, by the ratio of the observed
average concentration in drinking water to the
applicable RCG.
Tritiated water was discharged to Great Western
Reservoir, the water supply for the city of Broom-
field, as the result of an accidental release from the
Rocky Flats Plant during May 1973.9 Beginning
in October, water samples were collected weekly
from Great Western Reservoir and analyzed for
tritium. The average concentration of tritium in
Great Western Reservoir water during October-
December 1973, shown in Table 17, was 8.221
X 10~6 MCi/ml. This concentration is 0.82% of the
RCGW for tritium in water accessible to the
population at large. The dose commitment to an
individual drinking only water containing 8.221
X 10~6 ^Ci/ml tritium for seven months is
8X 10'4 rem.
For purposes of comparison, the annual natural
background dose commitment for a person living
in Colorado is about 0.2 rem, including external
radiation from radionuclides in soil, cosmic sources,
and internal radiation from natural radionuclides
such as potassium-40, which are incorporated in
biological material.
REFERENCES
1. Standards for Radiation Protection, U. S.
Atomic Energy Commission, AEC Manual,
Chapter 0524, 1968.
2. National Emission Standards for Ila/ardous
Air Pollutants. 40 CFR Part 61, Subpart C
(Proposed), U. S. Environmental Protection
Agency, 1971.
3. Standards for the Discharge of Wastes, Water
Pollution Control Commission, Colorado
Department of Health, 1972.
4. Secondary Treatment Information, 40 CFR,
Part 133, U. S. Environmental Protection
Agency, August 14, 1973.
5. "Standard Laboratory Procedures for the
Determination of Radioactivity and Chemical
Concentrations in Environmental and Bioassay
Samples," D. L. Bokowski, (Ed), USAEC
RFP-2039, Rocky Flats Division, Dow Chemical
U.S.A., to be published.
6. D. L. Bokowski, "Rapid Determination of
Beryllium by a Direct-Reading Atomic
Absorption Spectrometer,"Am. hid. Hyg.
Assoc., 29, Pp 474-481 (1968).
7. N. A.Talvitie./lra/. Chem., 43, pp 1827-1830
(1971).
8. D. E. Michels, "Diagnosis of Plutonium
Re-entrained in Air," USAEC RFP-1927, Rocky
Flats Divison, Dow Chemical U.S.A., April
27,1973. ,
9. "Investigation of the Tritium Release Occur-
rence at the Rocky Flats Plant," U. S. Atomic
Energy Commission, November 26, 1973.
10. "Investigative Report of the 1973 Tritium
Release at the Rocky Flats Plant in Golden,
Colorado." U. S. Environmental Protection
Agency, Region VIII, to be published, (1974).
11. Report of ICRP Committee II on Permissible
Dose for Internal Radiation (1959). Health
Physics?,, 1960.
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RFP-ENV-73
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10
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159
RFP-ENV-73
TABLES 1 through 17
Table 1. Airborne Radionuclides Released to Atmosphere.
Enriched Depleted Uranium
Plutonium Facilities Uranium Facilities and Research Facilities Beryllium Facilities
Month niCJ* fid** /iCi** grams***
January <11.36 < 0.69 < 3.19 <0.23
February < 3.49 < 0.31 < 2.14 <0.28
March < 2.44 < 1.54 < 1.10 <0.13
April < 3.79 < 5.49 < 1.58 <0.22
May < 2.88 < 0.54 < 1.96 <0.09
June < 2.16 < 0.26 < 8.09 <0.14
July < 2.83 < 0.44 <31.75 <0.33
August < 1.78 < 0.28 <'4.08 <0.34
September < 2.14 < 0.42 < 1.04 <0.55
October < 5.39 < 0.55 < 1.45 <3.32
November <30.68 < 0.04 < 2.4 <0.7S
December < 8.45 < 0.10 < 4.66 <0.70
Total <77.39 < 10.66 <63.44 <7.1
*Radiometncally determined as total long-lived alpha activity during January-June. Radiochemically determined as plutomum-239 during
July-December.
**Radiomctrically determined as totaUong-lived alpha activity.
***The USEPA discharge limitation for beryllium is 3,650 gramj/year.
11
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160
RFP-ENV-73
Table 2. Total Long-Lived Alpha Activity in Rocky Flats Ambient Air.
Volume-Weighted Station Averages Concentrations (X 10~15 pCi/ml).
Station
S-l
S-2
S-3
S-4
S-5
S-6
S-7
S-8
S-9
S-10
S-50
S-51
S-5 2
Volume-weighted average
January
<4.2±34%
<4.6 ± 22%
<4.9±51%
<4.5±37%
<4.1 ±28%
<3.8±30%
<4.5±25%
<5.1±31%
<4.4 + 33%
<4.2 1 33%
<5.5 ±54%
<5.1 ±35%
<4.4 ± 34%
<4.5±10%
Station
S-l
S-2
S-3
S-4
S-5
S-6
S-7
S-8
S-9
S-10
S-50
S-51
S-5 2
Summary
Volume-weighted average
n
122
120
115
118
81
122
114
117
121
111
121
96
103
1461
February
<5.0±28%
<4.9±32%
<5.0±28%
<4.1 ±30%
<4.2±35%
<4.2 ± 34%
<4.1 ±66%
<6.2±24%
<4.0±31%
<4.5 ±39%
<5.7±28%
<5.4 ±42%
<3.9±34%
<4.7 ± 9%
Match April
<8.7±123% <4.8±29%
<6.4± 62% <5.3±40%
<6.2± 40% <5.0±33%
<4.5± 38%
-------
RFP-ENV-73
Table 3. Plutonium in Rocky Flats Ambient Air.
Monthly Composite Station Concentrations (X 10~15 ^Ci/ml).
Station
S-l
S-2
S-3
S-4
S-5
S-6
S-7
S-8
S-9
S-10
S-50
S-51
S-5 2
Volume-weighted average
Station
S-l
S-2
S-3
S-4
S-5
S-6
S-7
S-8
S-9
S-10
S-50
S-51
S-5 2
Summary
Volume-weighted average
July
4.795
0.067
0.229
0.188
0.129
0.177
1.273
1.687
0.120
0.582
0.383
0.094
0.928
0.539 ±156%
6
6
6
6
6
6
6
6
6
6
6
3
6
75
August
September
October
November
<1.214± 99%
'Sampler out of service
*'Volume-weighted average
***RCGa for soluble plutonium-239 in ambient air accessible to incidentally exposed individuals is 60 X 10"
December
0.124
0.312
0.649
0.522
0.097
0.495
0.030
4.109
0.258
0.103
1 934
*
0.317
0.369 ±224%
0.105
0.160
0.061
0.148
0.095
0.134
0.604
1.017
0.304
0.233
0.691
*
0.182
0.211 ±106%
0.276
0.326
0.195
0.217
0.005
0.219
0.906
2.864
0.519
0.338
1.520
*
0.861
0.085
0.164
0.188
0.223
0.072
0.370
0.306
2.478
0.117
0.613
0.456
0.832
0.308
0.370 ±161% 0.497 ±77%
0.032
- 0.120
0.180
0.239
0.062
0.168
0.462
1.457
0.195
0.403
0.438
45.531
0.486
5. 375 ±138%
July-December 1973 Summary
Concentration (X 10"1!
Vol (m3)
11994.0
14765.0
14680.0
14765.0
177750.0
14684.0
14765.0
14765.0
14435.0
14033.0
11909.5
559320
14680.0
389157.5
r •
mm
0.032
0.067
0,610
0.148
0.005
0.134
<0.030
1.017
0.117
0.103
0.383
0.094
0.182
0.005
c
^max
4.795
0.326
0.649
0.522
0.129
0.495
1.273
4.109
0.519
0.613
1.934
45.531 i
0.928
45.531
uCi/ml)
r
avg
1.114±
0.190±
0.254 ±
0.258 ±
0.077 ±
0.266 ±
<0.588t
2.297 ±
0.248 ±
0.378 ±
0.699 ±
6.509 ±
0.507 ±
_
**
174%
58%
83%
54%
57%
53%
80%
50%
66%
55%
122%
1136%
66%
%of
RCGa***
1.8
0.3
0.4
0.4
0.1
0.4
<1.0
3.8
6.4
0.6
1.1
10.8
0.8
_
<2.0
13
-------
1S2
RFP-ENV-73
Table 4. Total Long-Lived Beta Activity in Rocky Flats Ambient Air.
Volume-Weighted Station Averages Concentrations (X 10~12
Station
S-l
S-2
S-3
S-4
S-5
S-6
S-7
S-8
S-9
S-10
S-50
S-51
S-5 2
Volume-weighted average
Station
S-l
S-2
S-3
S-4
S-6
S-7
S-8
S-9
S-10
S-50
S-51
S-5 2
Volume-weighted average
January
<0. 102 ±100%
<0.080± bQ%
<0.087± 32%
0.196 ± 56%
<0.106 ± 94%
<0.089± 78%
<0.112± 69%
<0.064 ± 4%
<0.084 ± 68%
<0.103 ±109%
<0 102± 66%
<0 150 ±131%
<0.063 ± 0%
<0.103± 17%
July
<0.123±52%
<0.137±57%
<0.123±78%
<0.185±61%
<0.136±45%
<0.167±71%
<0.136±76%
<0.148±47%
<0.092±77%
<0.113±60%
<0.127 ±43%
<0.108±63%
<0.135±16%
February
<0.112±188%
0.178 ±111%
<0.073 ± 61%
<0.122± 193%
<0. 139 ±696%
<0. 156 ±25 7%
<0.063 ± 0%
<0.138±234%
<0.063 ± 0%
<0.155±201%
<0.141 ±216%
<0.093±131%
<0.176±277%
<0.127± 26%
August
<0.108±285%
<0.197± 77%
<0.104± 36%
<0.166± 59%
<0.148±50%
<0.148± 86%
<0.147± 57%
<0.129± 50%
<0.157± 71%
*
*
<0.1 1 1 ± 49%
<0.144± 15%
March
-------
RFP-
Table 4. Total Long-Lived Beta Activity in Rocky Flats Ambient Air. (Continued)
Volume-Weighted Station Averages Concentrations (X 1CT12 /iCi/ml).
January-June 1973 Summary
Concentration (X 10"12 jjCi/ml)
Station
S-l
S-2
S-3
S-4
S-5
S-6
S-7
S-8
S-9
S-10
S-50
S-51
S-5 2
Summary
Volume-weighted average
S-l
S-2
S-3
S-4
S-6
S-7
S-8
S-9
S-10
S-50
S-S1
S-5 2
Summary
Volume-weighted average
S-l
S-2
S-3
S^l
S-5
S-6
S-7
S-8
S-9
S-10
S-50
S-51
S-5 2
Summary
Volume-weighted average
25
25
23
25
16
25
23
24
25
23
25
20
22
301
29
34
31
34
34
34
34
33
28
26
11
31
359
54
59
54
59
16
59
57
58
58
51
51
31
53
660
Vol (m3)
2037.5
2037.5
18745
2037.5
1304.0
2037.5
1874.5
1956.0
2037.5
1874.5
2037.5
1630.0
1793.0
24531.5
-
r .
nun
<0.0629
<0.0629
<0.0629
<0.0629
<0.0629
<0.0629
<0.0629
<0.0629
<0.0629
<0.0629
<0.0629
<0.0629
<0.0629
<0.0629
—
r
max
0.248 ±29%
0.298 ±27%
0.563 ± 19%
0.315 ±26%
0.420+22%
0.342*25%
0.508 t 20%
0.425 ±22%
0.376 ±24%
0.359 ± 24%
0.464 ±21%
0.331 ±25%
0.403 + 23%
0.563 ±19%
~
Cavg
<0.110±23%
<0.120±24%
<0.142±41%
<0.14S±26%
<0.157 ±43%
<0.112 ±26%
<0.152±32%
<0.144±30%
<0.105±28%
<0.110±34%
<0.142±34%
<0.125±31%
<0.132±37%
_
<0.130± 8%
July-December 1973 Summary
6601.5
3097.0
2852.5
3097.0
3097.0
3097.0
3097.0
3015.5
2608.0
2445.0
1141.0
6764.5
40913.0
-
January-
8639.0
5134.5
4727.0
51345
1304.0
5134.5
4971.5
5053.0
5053.0
4482.5
4482.5
2771.0
8557.5
65444.5
0.0273
<0.0839
<0.0839
<0.0839
<0.0839
<0.0839
<0.0420
<0.0839
<00839
<0.0839
<0.0839
<00120
<0.0)20
-
•December 1973
00273
<00629
<0.0629
<0.0629
<0.0629
<0.0629
<0.0629
<0 0420
<0.0629
<0.0629
<0.0629
<0.0629
<0.0120
<0.0120
0.368 ±28%
0.434 ±26%
0.478 ±24%
0.604 ±22%
0.339 ±29%
0.714 ±20%
0.640 ±21%
0.398 ±27%
0 309 ± 30%
0.294 ±31%
0.250 ± 34%
0.449 ± 25%
0.714 ±20%
Summary
0.368 ±28%
0.434 ± 26%
0.563 ±19%
0.604 ± 22%
0.420 ± 22%
0.342 ± 25%
0.714 ±20%
0.640 + 21%
0.398 ± 27%
0.359 ±24%
0464 ±21%
0.331 ±25%
0.449*25%
0.714 ±20%
<0.075 ±56%
<0.133±25%
<0.117 ±25%
<0.161 ±28%
<0.125 ±22%
<0.156±30%
<0.130±31%
<0.134±21%
<0.115 ±24%
<0,118±22%
<0.127±43%
<0.066 ±66%
_
<0.112±10%
<0-083 ±31%
<0.128±17%
<0.127 ±23%
<0.155 ±19%
•C0.157 ±43%
<0.120±16%
<0.155 ±21%
<0.135 ±21%
<0.122±16%
<0.113±19%
<0.129±20%
<0.126 ±24%
<0.080 ±42%
_
%of
<0.12
<0.14
<0.14
<0.16
<0.15
<0.14
<0.10
<0.14
<0.12
<0.13
<0.13
<0.08
<0.13
<0.12
<0.16
<0.12
<0.16
-------
RFP-ENV-73
Table 5. Plutonium in Two-to-Four-Mile-Distant Ambient Air.
Monthly Composite Station Concentrations (X 10~ls /jCi/ml).
Station
January
February
March
April
May
June
S-26
S-27
S-28
S-29
S-30
S-31
S-32
S-33
S-34
S-35
S-36
S-37
Volume-weighted average
Station
S-26
S-27
S-28
S-29
S-30
S-31
S-32
S-33
S-34
S-35
S-36
S-37
Volume-weighted average
0.161
<0.029
<0.018
<0.031
<0.013
<0.045
<0.049
<0.022
<0329
0.090
0.238
<0.177
<0.104±87%
July
0.007
0.010
0.017
*
*
0.020
0.032
0.008
0.012
0.007
0.017
0.008
0.014 ±58%
0.094
0.266
0.190
0.777
<0.156
0.087
0.196
0.184
0.202
<0.251
<0.150
<0.359
<0.195± 99%
August
0.003
0.003
<0.002
*
*
0.002
*
0.003
<0.002
0.006
0.003
0.0)8
<0.005 ±118%
0.045
0.134
<0.079
0.127
*
<0.111
0.340
0.051
0.046
<0.236
0.065
0.211
<0.128± 72%
September
0.013
0.004
0.005
*
*
0.006
0.005
0.010
0.007
0.005
0.006
0.105
0.017 ±187%
0.038
0.020
0.035
*
*
0.059
<0.002
0.025
0.029
0.020
0.039
0.018
<0.029± 54%
October
0020
0.010
0.265
*
*
0.005
0.007
*
0.219
0.014
0.012
0.008
0.061 ±183%
0.015
0.045
0.014
*
*
0.021
0.027
<0.002
0.021
<0.005
0024
0.013
<0.019±65%
November
0.014
0.012
0.005
*
*
0.023
<0.003
*
<0.003
0.022
<0.003
<0.003
<0.010±95%
, 0.151
0.064
0.057
*
*
0.043
0.044
0.174
0.015
0.053
0.050
0.141
0.078 ±72%
December
<0.003
0.007
0.011
*
*
<0.002
0.009
*
0.008
0.009
<0.003
0.007
<0.007±53%
'Sampler out of service.
16
-------
RFP-HNV-73
Table 5. Plutonium in Two-to-Four-Mile-Distant Ambient Air. (Continued)
Monthly Composite Station Concentrations (X 1CT15 /jCi/ml).
January-June 1973 Summary
Station
S-26
S-27
S-28
S-29
S-30
S-31
S-32
S-33
S-34
S-35
S-36
S-37
Summary
Volume-weighted average
167
1613021.5
Pu (Concentrations X 10"15 jjCi/ml)
n
16
16
J6
7
5
16
12
16
16
16
15
16
Vol(m3)
153965.5
151273.4
165765.2
21025.0
30119.0
164043.4
156857.5
165041.4
162015.8
156249.8
160923.7
125736.8
r
mjn
0.015
0.020
0.014
<0.031
<0013
0.021
<0.002
<0.002
0.015
<0.005
0.024
0013
r
max
0.161
0.266
0.190
0777
<0.156
<0.111
0.340
0.184
<0.329
<0.251
0.238
<0.359
cavg
0.073 ±
<0.089 +
<0 058 ±
<0.145 ±
<0.108±
<0.061 ±
<0.1!6 ±
<0.068 i
<0.088 ±
<0.103 ±
<0 080 ±
<0.115±
* *
142%
159%
18J%
1194%
938%
80%
164%
188%
234%
160%
171%
200%
RCG ***
a
0.36
<0.44
<0.29
<0.72
<0.54
<0.30
<0.58
<0.34
<0.44
<0.52
<0.40
<0.58
<0.002
0.777
<0.085 ± 54%
<0.42
July-December 1973 Summary
S-26
S-27
S-28
S-29
S-30
S-31
S-32
S-33
S-34
S-35
S-36
S-37
Summary
Volume-weighted average
6
6
6
*
*
6
5
3
6
6
6
6
152010.0
146090.0
170610.0
*
*
157830.0
148940.0
67265.0
145070.0
157460.0
165195.0
158550.0
0.003
0.003
<0.002
*
*
<0.002
<0.003
0.003
<0002
0005
<0.003
<0.003
0.020
0.012
0.265
*
*
0.023
0.032
0.010
0.219
0.022
0.017
0 105
0.009 ±
0.008 i
0.042 ±
*
*
0.010 +
0.011 ±
0.007 ±
0.034 +
0.011 ±
0.007 +
0.021 ±
128%
65%
375%
129%
200%
235%
390%
72%
138%
286%
0.04
0.04
0.21
*
*
0.05
0.06
0.04
0.17
0.06
0.04
0.10
56
1469020.0
<0.002
0.265
0.017+ 104%
0.08
January-December 1973 Summary
S-26
S-27
S-28
S-29
S-30
S-31
S-32
S-33
S-34
S-35
S-36
S-37
Summary
Volume-weighted average
22
22
22
7
5
22
17
19
22
22
21
22
3059755
297368.4
336375 2
21025.0
30119.0
321873.4
305797.5
227306.4
307085 8
313709.8
326118.7
284286.8
0.003
0.003
<0002
<0.03 1
<0.013
<0002
<0002
<0002
<0.002
<0.005
<0003
<0.003,
0.161
0.266
0.265
0.777
<0.156
<0 111
0.340
0.184
0.329
0.251
0.238
<0.359
0.041 ±
0.049 ±
<0.050 ±
-------
156
RFP-l'NV-73
Table 6. Total Long-Lived Alpha Activity in Ambient Community Air.
Volume-Weighted Station Averages Concentrations (X 1(T15 nC\/m\).
Community
Boulder
Broomficld
Coal Creek
Denver
Golden
Lafayette
Marshall
Wagner
Westminster
Volume-weighted average
January
<6.1 ± 96%
*
<1.3± 59%
6 8 ± 76%
-------
RFP-ENV-73
Table 7. Plutonium in Ambient Community Air.
Monthly Composite Station Concentrations (X 1CT15
Community
July
August
September
October
November
December
Boulder
Broomfield
Coal Creek
Denver
Golden
Lafayette
Marshall
Wagner
Westminster
<0.020
<0.015
<0020
<0020
10782
<0020
<0.050
<0.030
<0.020
0.018
<0.015
<0.015
*
<0.015
<0.015
0.035
0033
0.146
0.064
<0.015
0.028
<0.015
0.017
0.487
0.033
0.055
*
<0.015
<0.020
0.116
<0.020
<0.015
0.026
0.029
<0.030
*
<0.015
0.017
0.044
<0.015
<0.020
0.055
<0.030
<0.020
*
0.035
0.033
0.067
0.037
<0.015
0026
0068
<0.015
<0.030
Volume-weighted average <1.328±206% <0.023±181% <0.093 ± 144% <0.032±89% <0.027±46% <0.035 ±45%
Summary
Volume-weighted average
July-December 1973 Summary
Community
Boulder
Broomfield
Coal Creek
Denver
Golden
Lafayette
Marshall
Wagner
Westminster
n
6
6
6
5
6
6
6
6
3
Vol(m3)
18095.0
179190
15453.0
13207.0
16647.0
16611.0
10660.0
12303.0
4625.0
Conci
p
Snm
<0015
<0.015
<0.015
<0.015
<0015
<0.015
<0.029
-------
RFP-ENV-73
Table 8. Total Long-Lived Beta Activity in Ambient Community Air.
Volume-Weighted Station Averages Concentrations (X 10~n /iCi/ml).
Community
Boulder
Broomficld
Coal Creek
Denver
Golden
Lafayette
Marshall
Wagner
Westminster
Volume-weighted average
Community
Boulder
Broomficld
Coal Creek
Denver
Golden
Lafayette
Marshall
Wagner
Westminster
Volume-weighted average
January
<0,061 ± 57%
*
<0.024± 91%
<0 046 ±11 3%
<0.094 t 64%
<0.073± 40%
<0 118± 83%
<0.042± 15%
<0 110± 79%
<0051± 47%
July
0 086 ± 224%
0.059 ± 42%
0.081 ±100%
0.054 ±147%
0 037 ± 64%
<0 045 ± 142%
0.126 ± 194%
0.084 ± 50%
0.065 ± 34%
<0 066 ± 37%
February
<0 109 ±118%
*
<0 017 ±148%
<0.051 ±114%
<0. 154 ±170%
<0.128±119%
0 114 ± 72%
<0.042 ± 0%
<0.293 ± 179%
<0 067 ± 86%
August
0051 ± 56%
0041± 63%
0049± 68%
0.056 ± 68%
0 046 ± 20%
0.048 ± 52%
0.064 i 50%
<0 048 ± 60%
0.022 ± 0%
<0.049 ± 15%
March
<0.032±139%
0.043 ±165%
<0 028 ±141%
<0.049±577%
<0.053±193%
<0 030 ± 145%
<0 044 ± 194%
0034 ±263%
<0.035 ±151%
<0.038 ± 58%
September
0.035 ± 91%
0 048 ± 83%
<0.017 ±117%
<0 038 ±167%
0.060 ±118%
<0 029 ± 201%
<0.036± 71%
<0.048± 92%
*
<0039± 26%
April
<0.025 ± 69%
<0021 ±121%
<0.037± 88%
0.023 ± 57%
<0.019±120%
<0.033 ± 52%
<0.029± 94%
<0.025±174%
0.029 ± 87%
<0.026± 22%
October
<0.028 1 101%
0.040 ± 38%
0.056 ± 31%
<0.042± 95%
0.048 ± 56%
<0.041 ± 93%
<0.049±181%
<0.062± 92%
*
<0.044 ± 23%
May
0.028 ± 93%
0.023 ± 120%
0.030 ± 79%
0.032 ± 26%
0.027 ± 40%
0.029 ±114%
<0022± 66%
<0.028±174%
0.026 ± 52%
<0.027 ± 18%
November
0.036 ± 55%
0034 ± 61%
0.026 ± 53%
<0 028 ± 70%
0.024 ± 62%
<0.022 ± 53%
<0.030± 76%
<0.032± 57%
*
<0.029± 16%
June
•C0.027 ± 145%
<0.021 ± 87%
<0.020± 73%
0.026 ± 54%
<0.030 ±111%
<0.012± 36%
<0.024±221%
0.033 ± 42%
<0.028 ± 148%
<0.024± 25%
December
0 025 ± 90%
<0.026±101%
<0 030 ±136%
<0.018± 87%
0.043 ± 53%
<0.026±132%
<0.021 ± 46%
<0.032 ± 1049!
<0.023±212%
<0.027 ± 19%
*Samplcr out of service.
20
-------
Table 8. Total Long-Lived Beta Activity in Ambient Community Air. (Continued)
Volume-Weighted Station Averages Concentrations (X 1CT12 ;uCi/ml).
January-June 1973 Summary
169
RFP-ENV-73
Community
Boulder
Broomfield
Coal Creek
Denver
Golden
Lafayette
Marshall
Wagner
Westminster
n
26
16
26
23
26
26
26
20
25
Vol(m3)
9990 7
9193.9
13415.2
10083 5
9833.5
9605.5
7339.5
8045.1
8441.3
Co
mm
<0.0095
<0.0079
<0.0090
<00111
<00079
<0.0094
<00094
<0.0064
<0.0068
icenlration (X 10 '
^max
0 211 ±26%
0.089 ±51%
0.075 + 24%
0.324 ±26%
0 399 ±22%
0.259+27%
0.244 ±30%
0.1 14 ±38%
0.523 ±26%
MU/ml) anf
Cavg RCGa
<0.033 + 63% <0.
<0.025 ± 57% <0.
<0.026 ± 30% <0.
<0.031 ± 98% <0.
<0.036±101% <0.
<0.032± 80% <0
<0.037 + 77% <0.
<0.030± 50% <0.1
<0.036±146% <0.1
Summary
Volume-weighted average
214
85948.2
<0.0064
0.523 ±26%
<0.031 ± 30%
Boulder
Broomfield
Coal Creek
Denver
Golden
Lafayette
Marshall
Wagner
Westminster
Summary
Volume-weighted average
214
July-December 1973 Summary
26
26
25
26
26
26
26
26
7
18843
18639
15496
17140
17290
17208,
10973
12854
4421
.4
.4
.5
2
.0
.6
.2
.4
.6
<0.0089
<0.0106
<0.0106
<0.0091
<0.0096
< 0.0091
<0.0091
<0.0125
<0.0146
0
0
0
0
0
.265
.074
.154
.125
.123
0.103
0
0
0
.330
.123
.079
±16%
± 20%
±17%
± 1 9%
±16%
±19%
± 1 9%
+ 21%
+ 20%
<0
<0
<0
<0
0
<0.
<0.
042 ±
.042 ±
.042 ±
.039 ±
.042 ±
.035 +
,050 +
<0.049 +
<0.
.047 ±
49%
18%
32%
32%
21%
31%
59%
25%
48%
132867.3
<0.0089
0.330 ±19%
<0.2
<0.042± 12%
January-December 1973 Summary
Boulder
Broomfield
Coal Creek
Denver
Golden
Lafayette
Marshall
Wagner
Westminster
Summary
Volume-weighted average
52
42
51
49
52
52
52
46
32
28834
27833
28911
27223,
.1
.3
.7
.7
27123.5
26814
18312.
20899
12862,
.1
.7
.5
.9
<0.0089
<0.0079
<0 0090
<0(>091
<0.0()79
<0.0091
<0.0091
<0.0064
<0.0068
0.
0.
0.
0
0.
0.
0
0
0.
,265
,089
154
324
399
259
330
123
,523
±16% i
±51%
±17%
± 26%
± 22%
±27%
±19%
±21%
±26%
<0.039
<0
<0,
<0
<0.
<0.
<0.
<0
<0
.036
.035
,036
.040
034
.045
.041
.040
±
±
±
+
+
±
±
±
±
36%
19%
22%
41%
45%
39%
44%
22%
100%
218815.5
<0.0064
0.523 ±26%
<0.038 ± 14%
*Thc RCGa for total long-lived beta activity in ambient air accessible to the population at large is 33 X 10~
-------
170
RFP-KNV-73
Table 9. Annual Average Concentrations of Nonradioactive Constituents of Sewage Plant Effluent.
Parameter
Average
Most Restrictive Standard
Agency *
% of Standard
In range
84
In range
280
68
240
89
106
80
*CDH - Colorado Department of Health, Water Pollution Control Commission,
USEPA - U. S. Environmental Protection Agency.
*The USEPA and CDH standards for fecal coliform count and residual chlorine concentration are in conflict because 0.5 mg/l residual
chlorine has been determined as inadequate to reduce the fecal coliform count in Rocky Flats sewage plant effluent to the USEPA
limitation value.
PH
Fecal Coliform Count
Dissolved Oxygen
Residual Chlorine
Suspended Solids
Settleable Solids
BOD,
Turbidity
Color
7.5
168/100 ml
7.7 mg/l
1 4 mg/l
204 mg/l
1 2 ml/1
26.8 mg/l
32JTU
24 Units
6.0 to 9.0
200/1 00 ml**
>2.0 mg/l
0.1<(C1)<05 mg/l**
30 mg/l
0 5 ml/1
30 mg/l
30JTU
30 Units
CDH
USEPA
CDH
CDH
CDH
CDH
CDH
CDH
CDH
Table 10. Uranium +
Plutonium and Plutonium in Pond A-3 Water Samples.
U + Pu
(Concentration X 10"' nCi/ml)
Sample Period
January
February
March
April
May
June
6-mo. Summary
6-mo. Average*
July
August
September
October
November
December
6-mo Summary
6-mo Average*
Annual Summary
Annual Average*
%of RCGW**
n
4
4
5
4
3
5
25
-
4
5
4
4
5
4
26
51
-
-
c .
'-min
7.08
4.71
3.61
0.90
0.42
1.84
0.42
-
1 41
239
1 61
0.85
1.66
0.44
044
-
0.42
-
-
p
max
17.17
13.63
5.58
11.14
18.36
13.66
18.36
-
10.70
12.99
270
1.67
4.83
2.55
12.99
-
18.36
-
-
r *
avg
11.68 ± 51%
9.41 ± 64%
4.84 ± 18%
4.58 ±140%
7.71 ±225%
5.52 ±102%
-
7.10± 29%
3. 86 ±164%
5.96± 80%
2.22 ± 29%
1.21 ± 43%
2.63 ± 56%
1.46± 99%
-
3.00± 39%
_
5.01 ± 26%
0.31%
Pu
(Concentration X 10"' nCi/ml)
C .
min
<0.01
0.06
0.08
0.10
0.12
0.03
<0.01
-
0.10
0.03
OllS
0.06
0.05
0.02
002
-
<0.01
-
-
c
^max
1.34
0.24
0.16
0.51
0.32
0.51
1.34
-
0.32
0.64
0.61
0.32
2.35
0.45
2.35
-
2.35
-
—
C *
avg
<0.38±238%
0.14± 89%
Oil ± 31%
0.23 + 115%
025 i 81%
0.37 ± 62%
^
<0.24 ± 48%
0.21 ± 73%
0 3 1 ± 1 1 1%
0.36 i 89%
0.15 ±111%
0.70:1 156%
0 22 i 1 20%
-
0.34 ± 55%
-
<0.29 i 37%
<0.15%
'•U
'Sample-weighted average
**RCGW for soluble U + Pu is given by +
RCGW RCGpu
RCGW for soluble plutonium-239 is 1600 X 10"' ^iCi/
-------
171
RFP-l-NV-73
Table 11. Uranium + Plutonium and Plutonium in Pond B-4 Water Samples.
Sample Period
January
February
March
April
May
June
6-mo. Summary
6-mo. Average*
July
August
September
October
November
December
6-mo. Summary
6-mo. Average*
Annual Summary
Annual Average*
%of RCGW**
'Volume-weighted
**RCr, fnr snlnhlr
Vol
U + Pu
n (X 10« litcri) Cmln
4
4
5
4
3
5
25
-
4
5
4
4
5
4
26'
-
51
-
average.
II J- Pu i
27.3
22.2
29.6
69.7
243.0
36.7
428.5
--
22.0
10.6
23.0
20.0
12.0
26.0
113.6
542.1
-
-
it piven tv
23.05
32.94
14.26
4.90
0.93
15.06
0.93
-
9.72
9.64
4.35
4.23
3.40
3.84
3.40
-
3.40
-
-
CU
Cma\
53.27
81.48
45.61
20.37
16.87
90.19
90.19
-
24.03
13.76
9.48
7.89
7.04
8.31
24.03
-
90.19
-
-
cPu
<-i
p *
avg
38.68 ± 57%
65.42+ 47%
24.91 ± 56%
12.15+ 73%
10.88 ± 146%
35.24 + 101%
-
18.74 ± 55%
16.56 ± 49%
11.22+ 16%
6.39 ± 52%
5.37 ± 44%
5.62 ± 30%
5.92± 44%
-
8.43 ± 23%
-
16.58 t 36%
0.55%
whpre, RCGr, - 1(
Release
(mCi)
1 06
1.45
0.74
0.85
2.64
1.29
8.03
0.36
0.12
0.15
0.11
0.07
0.15
0.96
-
899
-
Pu
p
mm
12 96
7.75
6 83
1.24
0.18
5.61
0.18
-
7.83
6.79
3.56
2.08
2.57
2.98
2.08
0.18
p
max
45.27
57.67
26 18
12.39
3.59
24.17
57.67
-
22.37
11.62
6.53
6.93
466
6.35
22.37
-
57.67
-
p *
avg
25.67 ±
35.98 ±
12.19±
4.56±
1.86 ±
16.09 t
7.52 ±
15.31 ±
9.27 +
5.06±
3.88±
3.35 ±
4.05 ±
-
6.81 ±
-
7.37 ±
84%
84%
80%
161%
169%
54%
86%
54%
27%
40%
76%
29%
53%
29%
47%
Release
(mCi)
0.70
0.80
0.36
032
0.45
0.59
3.22
-
0.34
0.10
0.12
0.08
0.04
0 10
0.78
-
4 00
-
- 0.46%
vnon x i
n-' iiC.i/rr
il and RCC
"•.D.. - 16(1
10 y ir
1'' uCi/ml
RCGij RCGpu
RCG for soluble plutonium-239 is 1600 X 10"
r
-------
172
RFP-ENV-73
Table 12. Uranium + Plutonium and Plutonium in Pond C-1 Water Samples.
Sample Period
January
I'cbruary
March
April
May
June
6-mo. Summary
6-mo Average*
July
August
September
October
November
December
6-mo. Summary
6-mo Average*
Annual Summary
Annual Average*
'/ofRCG **
52
U-r Pu
(Concentration X 10"' jiCi/ml)
Pu
(Concentration X 10"' uGi/ml)
n
4
4
5
4
4
5
26
-
4
5
4
4
5
4
26
Cmm
1 26
1 78
1.09
0 87
<001
032
<001
-
0.25
0.52
069
041
062
0.67
025
r
max
11 90
11.57
3.21
1 99
7 30
245
11.90
0.92
3 83
2.02
281
1 21
1 57
3.83
r
avg
5 16 ±
5.69 +
2.16 +
1 50 +
<239±
093 +
-
<2.86 ±
059±
1.49±
1.15 +
1.23 ±
0 87 +
0.96 ±
-
*
128%
108%
49%
52%
193%
109%
45%
64%
103%
74%
122%
32%
61%
cmm
<001
<0.01
002
004
<-o.oi
002
<0.01
005
0.04
009
006
0.04
003
0.03
r
max
1 67
0 12
0.06
0 20
0.09
0.54
1.67
-
0.07
0.41
0.13
0.22
0.52
061
0.61
C '
avg
<0.56 ±
<0.05 ±
0 04 ±
Ollt
<0.05 ±
0.23 1
-
<0.17 ±
006±
0 23 ±
0.11 ±
0.11 ±
0.30 ±
0 31 ±
-
k
194%
139%
57%
88%
111%
100%
81%
23%
109%
25%
101%
80%
148%
<001
11 90
i 06 ±
1 96 + 35%
0.03%
1.67
*Samplc-weightcd average
**RCGW lor soluble U + Pu is given by -
0.19 ± 40%
<0.18 ± 42%
<001%
RCG,j RCGpu
RCG for soluble plutonium-239 is 1600 X 10'' nCi/
<1 where RCGy = 10,000 X 10"' ,uCi/ml and RCGpu = 1600 X 10"
Table 13. Americium-241 in Water Samples.*
Location
Pond B-4
Walnut Creek at Indiana Street
Great Western Reservoir
Standlcy Lake
Concentration X 10"'
n
19
20
5
5
r
""mm
<0.01
<0.01
<0.01
<001
r
^max
16.86
8.96
0.45
0.78
c **
avg
<1.79 ± 122%
<1.31 ± 81%
<0.16 ±148%
<020±185%
-------
RFP-
Table 14. Uranium + Plutonium and Plutonium in Walnut Creek.
U + Pu
(Concentration X 10"
Sample Period
January
February
March
April
May
June
6-mo. Summary
6-mo. Average*
July
August
September
October
November
December
6-mo. Summary
6-mo. Average*
Annual Summary
Annual Average*
%ofRCGw***
n
4
4
5
4
4
5
26
-
4
5
3
4
5
3
24
.
50
-
—
Cmin
998
15.74
6.30
3.21
3.23
2.20
2.20
-
1.34
0.73
0.98
1.68
1.54
2.78
0.73
-
0.73
-
—
cmax
36.02
33.71
17.05
7.69
166.36**
16.92
166.36**
-
360
2.62
4.28
6.41
3.26
4.21
6.41
-
166.36**
-
-
9 nCi/mt)
r *
avg
22.00± 74%
25.38± 41%
10.96 ± 54%
5.21 ± 56%
51.55 ±209%
7.93 ± 99%
-
19.65 ± 65%
2.84 ± 50%
1.65 ± 48%
2.34 ± 136%
3.01 ±105%
2.19± 35%
3.56 ± 37%
-
2.5 1± 22%
-
11.43 ± 60%
0.27%
Pu
(Concentration X 10
cmin
3.34
5.08
1.56
0.30
0.09
0.78
0.09
-
1.09
0.30
0.46
0.26
0.59
0.39
0.26
-
0.09
-
-
Cmax
21.18
14.69
8.21
5.44
1.01
10.21**
21.18
-
2.30
0.84
3.62
0.88
1.39
3.01
3.62
-
21.18
-
-
-' MCi/ml)
r *
'-•avg
11. 79 ±102%
10.57 ± 53%
3.35 ± 95%
1.85 ±183%
0.63 ± 97%
3.03 ±153%
-
5.05 ± 46%
1.56 ± 49?-
0.5 2 ± 51%
1.64 ±194%
0.60 ± 60%
0.78 ± 61%
1.39 ±188%
_
1.01 ± 35%
-
3.11 ± 43%
0.19%
* Sample-weigh ted average.
**Suspect data. The values as shown are included in the computation of averages.
Ci / Cp,.
***RCG for soluble U + Pu ij given by -
RCGij RCGpu
where RCGij = 10,000 X 10'' MCi/ml and RCGPu = 1600 X 10 ' MCi/ml.
RCG for soluble plutonium-239 is 1600 X 10-
-------
774
RFP-ENV-73
Table 15. Uranium + Plutonium and Plutonium in Public Water Supplies. Annual Average* Concentrations (X 1CT9 pCi/ml).
U + .Pu
Pu
Rcsctvovrs
Great Western
Standley Lake
Finished Water
Arvada
Boulder
Broomfield
Denver
Golden
Lafayette
Louisville
Thornton
Westminster
n
15
14
15
15
14
15
15
15
15
13
15
c
vmm
0.26
0 13
004
<0.01
0.09
009
0.11
0.02
<001
0 11
008
max
9.38
9.33
23.60
2.55
13 23
975
14.06
3.85
2.14
113.12
5.35
r *
avg
3 00 ±49%
3.63 ±48%
3.64 ±93%
< 0.6 8 ±70%
2.7 3 ±84%
2 88 ±57%
3.01 ±70%
0.95 ± 69%
< 0.44 ± 75%
21.74 ±91%
1.02 ±76%
%of
RCGW«
003
0.04
0.04
<0.01
0.03
0.03
003
0.02
<001
0.22
001
mm
<0.01
<0.01
<0.01
<001
<001
<001
<0.01
<0.01
<0.01
<0.01
<0.01
^•max
0.31
0.17
0.20
0.57
0.49
0.55
0.12
0.85
0.29
0.70
0.32
r *
avg
<0.08± 59%
<0.04 ± 69%
<0.03 ± 93%
<0.09 ± 98%
<0.11 ± 74%
<0.08 ±114%
<002± 79%
<0.11 ±105%
<0.05 ± 90%
<0.12±105%
<0.04 ± 108%
%of
RCGW"
<0.005
<0.002
<0.002
<0006
<0.007
<0.005
<0.001
<0007
<0.003
<0.008
<0.002
Reservoir Summary 29
Rescrvok Average*
Finished Water Summary 132
Finished Water Average*
0 13
9.38
<0.01 0.31
<0.01 113.12
.< 3 31 ±32%
< 3.87 ±54%
<0.03
<0.04
<0.01
0.85
<0.06 ± 45%
<0.07 ± 34%
'Sample-weighted average
**RCGW for soluble U + Pu is given by
RCG
CPU
RCGij RCGPu
for soluble plutonmm-239 is 1600 X 10"' jjCi/ml
-------
RFP-
FIGURES1 through 9
c
D
E
o
o
•a
c
e/3
•g
aj
«-«
C
—
Q-
o
tr
O
I
+*
S
o
I
.1
27
-------
17&FP-ENV-73
B-2 B-3 B-4 SOUTH WALNUT
CREEK
Figure 2. Liquid Effluent Water Courses.
-------
FP-EN\
RFP-ENV-73
Not to scale.
Figure 3. On-Site Air Sampling Stations.
Figure 4. Off-Site Air Sampling Stations. The larger dots represent community samplers.
Rocky Flats Plant
(93)* (13 air samplers)
I Lafayette
- Air Samplers
N
28>—•* wj Broomfield
Indiana St.
Westminster
-------
P-HNV-73
0.400
0.350
0.300
e
0
. 0.250
Z 0.200
O
0.150
UJ
O
Z
8 0.100
0.050
t
RCG = 20 x 10
JAN
FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC
Figure 5. Plutonium-239 in 2- to 4-Mile Distant Ambient Air.
(Volume-Weighted Monthly Average Concentrations.)
Figure 6. Plutonium-239 in Pond B-4 Water Samples.
(Volume-Weighted Monthly Average Concentrations.)
80
~T
"T
T
70
60
t
RCG = 1600 x 10 '/aCi/ml
40
30
O 20
o
10
JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC
-------
FEN V-73
c
o
c
0)
o
c
o
o
c
s
J3
a
u
c
o
O
-------
180
RFP-IiNV-73
ELDORADO
SPRINGS
Scale: One inch equals one mil
Figures. Plutonium Concentrations in Soil. Concentrations X 10"6 M.C
background from fallout is 225 X 1CT6 /jCi/m2 .
= d/m/g X 4.5 X 10 3. The average worldwide
-------
181
RFP-ENV-73
o
a.
i
o
z
z
LU
O
z
o
o
40
35
30
25
20
15
10
t
RCG = 1000 x 10~6MCi/ml
_L
I
I
_L
I
WEEK OF 10/15 10/22 10/29 11/5 11/12 11/19 11/26
Figure 9. Tritium in Landfill Seepage. (Weekly Average Concentrations).
12/3
12/10 12/17 12/24
-------
18
9
'•"RFP-ENV-73
THIS PAGE INTENTIONALLY LEFT BLANK
-------
183
Dr. Mills: We next have the Colorado Department of
Health. This is Mr. Al Hazle from the Colorado Department
of Health.
Mr. Hazle: My name is Albert J. Hazle. I am the
Director of the Division of Occupational and Radiological
Health with the State Department of Health.
-------
-------
STATEMENT
U, S, ENVIRONMENTAL PROTECTION AGENCY, DENVER, COLORADO
HEARINGS ON PLUTONIUM STANDARDS DEVELOPMENT
BY
THE COLORADO DEPARTMENT OF HEALTH
THE DEPARTMENT WISHES TO TAKE THIS OPPORTUNITY TO INFORM THE HEARING
OFFICERS OF WHAT COLORADO EXPERIENCED IN SETTING ITS PLUTONIUM-IN-SOIL
STANDARD AND ITS FEELINGS ON THE NECESSITY OF HAVING CONSERVATIVE STANDARDS
WHEN THE GENERAL PUBLIC'S HEALTH IS AT RISK.
IN FEBRUARY OF 1970, THE COLORADO DEPARTMENT OF HEALTH INITIATED A SOIL
SAMPLING PROGRAM TO EVALUATE PLUTONIUM CONTAMINATION IN THE VICINITY OF THE
USAEC1 ROCKY FLATS PLANT. THIS PROGRAM WAS UNDERTAKEN AFTER IT WAS IDENTIFIED
BY THE COLORADO COMMITTEE FOR ENVIRONMENTAL INFORMATION, THAT PLUTONIUM FROM
. THIS FACILITY HAD BEEN RELEASED TO THE ENVIRONS. THE DEPARTMENT DESIGNED A
SOIL SAMPLING PROGRAM TO PROVIDE THE MOST MEANINGFUL DATA WITH REGARD TO ANY
POTENTIAL PUBLIC HEALTH HAZARD. IN THIS INSTANCE, THE HAZARD ASSOCIATED WITH
PLUTONIUM IN SOIL RESULTS FROM THE INHALATION OF THE RADIOACTIVE MATERIAL"
WITH SUBSEQUENT DEPOSITION IN THE LUNGS AND OTHER ORGANS. ANNUAL SAMPLING IS
NOW CONDUCTED NORMALLY IN THE SPRING WHEN SNOW HAS MELTED AND WHILE VEGETATION
IS AT ITS SEASONAL MINIMUM.
THE DEPARTMENT'S SOIL SAMPLING PROGRAM HAS DIVIDED THE AREA AROUND THE
PLANT SITE INTO 13 SECTORS. THESE SECTORS ARE LOCATED AT 1, 3 AND 6 MILE
RADIAL DISTANCES FROM THE PLANT BOUNDARY. 25 SOIL SAMPLES ARE COLLECTED IN
EACH SECTOr. MOST IMPORTANTLY, THE SAMPLES ARE COLLECTED FROM THE TOP
1/8 INCH OF UNDISTURBED SOIL WHICH WOULD BE INDICATIVE OF THE HEALTH HAZARD
POTENTIAL. SAMPLING OF LOCATIONS WHERE PLOWING OR OTHER DISTURBANCES HAVE
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OCCURRED IS AVOIDED DUE TO THE QUESTIONABLE RESULTS OF SUCH SAMPLING FOR
IDENTIFICATION OF THE POTENTIAL HAZARD. SAMPLING IS NOT ACCOMPLISHED EITHER
UNDER OR IMMEDIATELY ADJACENT TO BUNCH-GRASS CLUMPS WHICH ARE COMMON TO THE
NATURAL VEGETATION OF THE AREA. THIS IS DONE TO PRECLUDE THE WIDE VARIANCES
OF RESULTS WHICH WOULD ARISE DUE TO THE DEPOSITION AND RETENTION OF MATERIAL
IN SUCH CIRCUMSTANCES WITH REGARDS TO RESUSPENSION TO AN AIRBORNE HAZARD. THE
25 SOIL SAMPLES COLLECTED IN EACH SECTOR ARE COMPOSITED FOR A SECTOR ANALYSIS.
A TOTAL OF 325 SOIL SAMPLES ARE COLLECTED IN TFE 13 SECTORS IN THE IMMEDIATE
ROCKY FLATS PLANT ENVIRONS.
TO ESTABLISH THE CONCENTRATION OF PLUTONIUM IN THE TOP 1/8 INCH OF UNDIS-
TURBED SOIL THAT IS ATTRIBUTABLE TO WORLD-WIDE FALLOUT, 8 "BACKGROUND" AREAS ON
THE EASTERN SLOPE OF COLORADO ARE SAMPLED WITH A TOTAL OF 200 ADDITIONAL SAMPLES
COMPOSITED ANNUALLY FOR THOSE 8 AREAS.
IN 1970, PLUTONIUM ANALYSIS OF SAMPLES WAS PERFORMED FOR COLORADO BY THE
U. S. ENVIRONMENTAL PROTECTION AGENCY'S LABORATORY IN LAS VEGAS, NEVADA. THE
SPECIFIC PLUTONIUM ANALYSIS DONE ON THE SAMPLES FROM 1971 TO THE PRESENT HAS BEEN
ACCOMPLISHED BY THE COLORADO DEPARTMENT OF HEALTH AT ITS OWN COUNTING FACILITY IN
DENVER. THE METHOD OF ANALYSIS IS THROUGH THE USE OF A PROCEDURE DEVELOPED BY
N. A. TALVITIE, EPA, LAS VEGAS, NEVADA.
IN ADDITION TO THE SOIL SAMPLING DONE BY THE COLORADO DEPARTMENT OF HEALTH,
VARIOUS OTHER AGENCIES AND GROUPS HAVE DONE SOIL SAMPLING IN REGARD TO THE PLUTO
NIUM CONTAMINATION IN THE ROCKY FLATS PLANT ENVIRONS. THE HEALTH AND SAFETY
LABORATORY OF THE USAEC HAS ACCOMPLISHED SEVERAL STUDIES IN THE DENVER METROPOL-
ITAN AREA. THE SOIL SAMPLING ACCOMPLISHED BY THESE STUDIES IS LIMITED, AND
DIFFERENT SOIL SAMPLING TECHNIQUES HAVE BEEN USED WITH SOME SOIL ALIQUOTS BEING
TAKEN AT DEPTHS DOWN TO 20 CENTIMETERS OR ABOUT 8 INCHES. THE MAJOR
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IMPACT OF THESE STUDIES WAS TO IDENTIFY THE AREA IMPACTED BY THE SPREAD OF
PLUTONIUM FROM THE ROCKY FLATS PLANT AND TO ESTIMATE THE INVENTORY OF PLUTO-
NIUM LOST.
DOW CHEMICAL U. S. A., ROCKY FLATS DIVISION, THE PRESENT PLANT OPERATOR,
HAS PERFORMED ANALYSIS ON MANY INDIVIDUAL SOIL SAMPLES COLLECTED BY VARIOUS
MEANS THROUGHOUT THE PLANT ENVIRONS AND IN AREAS AWAY FROM THE IMPACT OF PLANT
OPERATIONS. THE RESULTS OF THEIR SAMPLING PROGRAMS HAVE BEEN PUBLISHED IN
THEIR ANNUAL SURVEILLANCE SUMMARIES.
DR. STEWART POET AND DR. EDWARD MARTELL OF THE COLORADO COMMITTEE FOR
ENVIRONMENTAL INFORMATION ALSO DID SOIL SAMPLING IN THE ENVIRONS OF THE ROCKY
FIATS PLANT. THE TECHNIQUE USED WAS TO SELECT INDIVIDUAL SAMPLE LOCATIONS
AND SAMPLE THE TOP ONE CENTIMETER DEPTH OF SOIL. SOME DEPTH SAMPLING WAS ALSO
ACCOMPLISHED, AND THE RESULTS OF THEIR SAMPLE ANALYSIS HAS BEEN PUBLISHED IN
THE SCIENTIFIC LITERATURE.
OF ALL THE SOIL SAMPLING PROGRAMS THAT HAVE BEEN DESCRIBED, THE COLORADO
DEPARTMENT OF HEALTH'S PROGRAM APPEARS TO BE THE ONLY ONE SPECIFICALLY ADDRESSED
TO THE RESUSPENSION OF PLUTONIUM FROM THE TOP LAYER OF SOIL AND LENDS ITSELF
TO LARGE SCALE LAND USE EVALUATION OF THE POTENTIAL PLUTONIUM HAZARD. BECAUSE
HAZARD ANALYSIS BASED ON SOIL DATA NORMALLY UTILIZES ARBITRARY RESUSPENSION
"AIR CONCENTRATION HALF-LIFE" FACTORS WHICH MAY NOT BE APPROPRIATE TO THE
SPECIFIC SITUATION EXISTING IN THE ENVIRONS OF ROCKY FLATS, THE ONLY PROPER
METHOD TO EVALUATE THE SITUATION IS BY AIR SURVEILLANCE.
AIR SAMPLING SURVEILLANCE STATIONS OF THE COLORADO DEPARTMENT OF HEALTH HAVE
BEEN ESTABLISHED ON THE ROCKY FLATS PLANT SITE AND HAVE BEEN IN OPERATION SINCE
MAY, 1970, IN AN AREA IMMEDIATELY ADJACENT TO THE SOURCE OF THE PLUTONIUM FOUND
IN THE OFFSITE ENVIRONS. THE AIR SAMPLING STATIONS IMMEDIATELY ADJACENT TO THE
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MOST HIGHLY CONTAMIHATED GROUND INDICATE AN ANNUAL AVERAGE OF 0.006 FICO-CURIES
PER CUBIC METER OF AIR AS A COMPOSITE AVERAGE OVER THE PERIOD OF TIME THAT HAS
BEEN SAMPLED AND ANALYSED TO DATE. MAXIMUM INTEGRATED SAMPLE CONCENTRATIONS
OBSERVED OVER THE YEARS HAVE BEEN IDENTIFIED TO BE DUE TO VEHICULAR TRAFFIC OR
EXCAVATION WORK IN THE IMMEDIATE VICINITY OF THE AIR SAMPLERS AND NOT SPECIFICALLY
DUE TO THE OCCURRANCE OF HIGH WINDS. INSTANTANEOUS MAXIMUM CONCENTRATIONS WOULD
BE IN EXCESS OF THE MAXIMUM PERMISSIBLE CONCENTRATION FOR LARGE SEGMENTS OF THE
GENERAL POPULATION (0002 pCi/M3) BY SEVERAL ORDERS OF MAGNITUDE. IT MUST DE
REMEMBERED, HOWEVER, THAT CONCENTRATIONS IN SOIL IN THIS AREA ARE CONSIDERABLY
HIGHER THAN THOSE FOUND OFFSITE, AND, THAT REFERENCE TO AIR CONCENTRATION
STANDARDS FOR THE GENERAL POPULATION WOULD NOT BE APPLICABLE.
EVALUATIONS FOR HEALTH IMPACT DONE BY THE COLORADO DEPARTMENT OF HEALTH ARE
PRIMARILY BASED ON RESULTS OF AIR SAMPLING ANALYSIS. THE AIR SAMPLING THAT WAS
ESTABLISHED BY THE DOW CHEMICAL COMPANY AND THE STATE HEALTH DEPARTMENT IDENTIFIED
THAT THE RURAL SITUATION WHICH PRESENTLY EXISTS IN THE IMMEDIATE ROCKY FLATS
ENVIRONS DOES NOT POSE A SERIOUS THREAT TO HEALTH. HOOVER, THE RURAL SAMPLING
RESULTS CANNOT BE EXTRAPOLATED TO AN UNKOWN URBAN ENVIRONMENT SITUATION WHICH IS
BEING ANTICIPATED FOR THE AREA.
DURING THE 1972 SESSION OF THE COLORADO STATE LEGISLATURE AX ."— f"Eir --P
CHAPTER 106 OF THE COLORADO REVISED STATUTES WAS ENACTED (SENATE BILL 35). AS THE
DEPARTMENT VIEWS THIS ACT, IT WAS THE INTENT OF THE LEGISLATURE THAT ANY PLATTING
AGENCY, BE IT MUNICIPAL OR COUNTY, REQUIRE A RADIATION EVALUATION FROM A SUB-
DIVIDER WHERE THERE IS A POTENTIAL RADIATION HAZARD KNOWN OR PRESUMED KNOWN
TO EXIST IN THE AREA TO BE DEVELOPED. A MEETING WAS HELD AT THE STATE HEALTH
DEPARTMENT ON OCTOBER 25, 1972, WITH THE AEC AND EPA IN ATTENDANCE AT THE REQUEST
OF THE STATE HEALTH DEPARTMENT. THE PURPOSE OF THIS MEETING WAS TO DISCUSS THE
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AVAILABILITY OF STANDARDS FOR PLUTONIUM IN SOIL TO MEET THE REQUIREMENTS OF
THE ABOVE STATED LAW. IT WAS DETERMINED THAT THERE WERE NO NATIONAL OR INTER-
NATIONAL ACCEPTED STANDARDS FOR PLUTONIUM CONTAMINATION IN SOIL, AND THAT THE
ONLY AVAILABLE INFORMATION WAS FROM INDIVIDUALS WITH NO OFFICIAL RESPONSIBLE-
AGENCY STATUS. THE REPRESENTATIVE FROM EPA, STANDARDS AND CRITERIA BRANCH,
OFFICE OF RADIATION PROGRAMS, STATED THAT HIS AGENCY HAD ESTABLISHED A PRIORITY
FOR THE GENERATION OF A PLUTONIUM-IN-SOIL STANDARD AT THE REQUEST OF THE STATE
HEALTH DEPARTMENT. HOWEVER, IT WAS ANTICIPATED THAT THIS STANDARD WOULD NOT BE
AVAILABLE FOR APPROXIMATELY 2 YEARS.
IN DECEMBER OF 1972, a "SUGGESTED INTERIM GUIDANCE" WAS PROVIDED TO THE
COUNTY COMMISSIONERS INFORMING THEM OF THE DEPARTMENT'S FEELING TOWARD THE
CONTENT OF THE REQUIRED RADIATION EVALUATION. THIS GUIDANCE DID NOT INCLUDE A
STANDARD. AN "AREA OF CONCERN" WAS IDENTIFIED FOR THE ENVIRONS OF THE ROCKY
FIATS PLANT USING THE THEN AVAILABLE SOIL CONCENTRATION DATA FROM ALL PARTIES
AND WAS INCORPORATED IN THE GUIDELINES. A REVIEW OF THE SUBMITTED DATA AND
RECOMMENDATIONS REGARDING LAND USE WERE TO BE ACCOMPLISHED BY THE STATE HEALTH
DEPARTMENT. IT WAS HOPED BY ALL CONCERNED THAT THERE WOULD BE NO DEVELOPMENT
OF LAND WHICH HAD A SIGNIFICANT CONCENTRATION OF PLUTONIUM IN SOIL UNTIL THE
EPA STANDARDS WERE AVAILABLE.
THE DEPARTMENT WAS SUBSEQUENTLY INFORMED OF PLANS FOR THE DEVELOPMENT OF
AN AREA LOCATED APPROXIMATELY FROM WEST 98TH AVENUE TO WEST 104TH AVENUE, AND
FROM ALKIRE STREET TO SIMMS STREET, (EAST OF THE PLANT SITE), THAT WERE TO BE
PRESENTED TO THE WESTMINSTER CITY PLANNING COMMISSION. AS THE LAW SPECIFICALLY
REFERRED TO ACTIONS BY BOARDS OF COUNTY COMMISSIONERS, THE DEPARTMENT NOTIFIED
ALL ADJACENT MUNCIPALITIES TO THE ROCKY FLATS ENVIRONS OF THE REQUIREMENTS OF
SENATE BILL 35 AND PROVIDED THE "SUGGESTED GUIDANCE" WHICH HAD BEEN PREVIOUSLY
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SENT TO THE BOARDS OF COUNTY COMMISSIONERS.
BECAUSE OF THE NEEDS OF THE LAND OWNER, THE DEVELOPER, THE CITY AND COUNTY
PLANNING COMMISSIONS, AND PLATTING AGENCIES, AND THE SEEMINGLY INCONSISTENCY
OF SENATE BILL 35 WITH REGARD TO MUNICIPALITIES AND COUNTY GOVERNMENTS, THE
COLORADO DEPARTMENT OF HEALTH ESTABLISHED, AT THE REQUEST OF THE BOARD OF HEALTH,
AN EMERGENCY INTERIM STANDARD FOR PLUTONIUM IN SOIL IN JANUARY OF 1973. THIS
EMERGENCY STANDARD, WHICH BY LAW COULD BE IN EFFECT FOR 90 DAYS, READ AS FOLLOWS:
"IN UNCONTROLLED AREAS WHERE THE TOTAL CONCENTRATION OF PLUTONIUM IN THE SOIL IS
IN EXCESS OF 0.2 DISINTEGRATIONS PER MINUTE PER GRAM OF DRY SOIL, SUCH LAND SHALL
BE UNFIT FOR RESIDENTIAL USE, SUBDIVISION DEVELOPMENT, Oil COMMERCIAL AND INDUS-
TRIAL USES." ON JANUARY 24, 1973, A NOTICE OF PUBLIC HEARING BEFORE THE STATE
BOARD OF HEALTH WAS ANNOUNCED REGARDING PUBLIC HEARINGS ON THE ADOPTION OF RULES
AND REGULATIONS PERTAINING TO THE PERMISSIBLE LEVELS OF RADIOACTIVE MATERIAL IN
UNCONTROLLED AREAS (PLUTONIUM). A PROPOSED STANDARD, AND THE EMERGENCY STANDARD
THEN IN FORCE, WAS BASED ON THE BACKGROUND CONCENTRATIONS IDENTIFIED FOR AREAS
OUTSIDE OF THE POSSIBLE INFLUENCE OF THE ROCKY FLATS PLUTONIUM CONTAMINATION.
AN AVERAGE BACKGROUND CONCENTRATION OF 0.08 DISINTEGRATIONS PER MINUTE OF PLUTO-
NIUM PER GRAM OF DRY SOIL WAS MULTIPLIED BY A FACTOR OF 2 AND ROUNDED TO THE
NEAREST SIGNIFICANT DIGIT TO A CONCENTRATION OF 0.2 DISINTEGRATIONS PER MINUTE
OF PLUTONIUM PER GRAM OF DRY SOIL. THIS STANDARD WAS BASED ON THE SAMPLING
PROCEDURES AND RESULTS ESTABLISHED BY THE DEPARTMENT. THE DEPARTMENT'S SAMPLING
TECHNIQUE IS RELATIVELY SIMPLE, AND SAMPLING AND MEETING THE REQUIREMENTS OF THE
LAW AND ITS RADIATION HAZARD EVALUATION COULD BE ACCOMPLISHED WITH RELATIVE EASE.
STANDARDS PROPOSED OR USED BY SPECIFIC GROUPS OR AGENCIES FOR THEIR OWN
PARTICULAR NEEDS, WHICH HAD BEEN FACTORED DOWN FROM OCCUPATIONAL EXPOSURES TO
LEVELS FOR THE GENERAL POPULATION AT THE MAXIMUM PERMISSIBLE DOSE ARE UNACCEPTABLE.
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EXAMPLES OF SUCH EFFORTS ARE AS FOLLOWS: DR. WRIGHT LANGHAM PROPOSED IN
1968 THAT A SOIL CONCENTRATION OF 100 MICRO-GRAMS OF PLUTONIUM PER SQUARE
METER (OR 1380 DPM PER SQUARE CENTIMETER) WAS APPROPRIATE FOR A ONCE-IN-A-
LIFE-TIME INCIDENT. THE RECOMMENDATION WAS BASED ON A 110 DAY AIR CONCEN-
TRATION HALF-LIFE, INSOLUBLE PLUTONIUM 239, AND A RESUSPENSION FACTOR OF
7 X 10 PER METER. (IT SHOULD BE NOTED HERE THAT DENMARK, REGARDING THE
THULE INCIDENT, REQUIRED THE USE OF A RESUSPENSION FACTOR OF 1 X 10 PER METER.)
IN A 1969 PAPER, DR. LANGHAM MADE NO RECOMMENDATION FOR SOIL CONTAMINATION
LEVELS; HOWEVER, USING A NEW ICRP LUNG MODEL, HE MADE RECOMMENDATIONS BASED ON
DOSE, AND THE SIZE OF POPULATION AFFECTED. IN HIS JUDGEMENT, AS THE DOSE
COMMITMENT INCREASED, THE NUMBER OR SIZE OF POPULATION SHOULD BE APPROPRIATELY
REDUCED. HERE, AGAIN, THE RECOMMENDATIONS WERE BASED ON A ONCE-IN-A-LIFE-TIME
INCIDENT. IN A PAPER ENTITLED "TOWARD INTERIM ACCEPTABLE SURFACE CONTAMINATION
LEVELS FOR ENVIRONMENTAL PLUTONIUM OXIDE" BY R. L. KATHREN, PUBLISHED IN APRIL,
1968 ( A BATTELLE NORTHWEST LABORATORIES PUBLICATION) AN URBAN STANDARD WAS PRO-
POSED. THE PROPOSAL IS A VALUE EQUIVALENT TO AN AVERAGE OF 10 DISINTEGRATIONS PER
MINUTE PER SQUARE CENTIMETER. IT SHOULD BE NOTED THAT THE PROPOSAL IS BASED ON
THE MAXIMUM PERMISSIBLE DOSE TO AN INDIVIDUAL OF THE POPULATION AND NOT BASED ON
THE VALUE THAT SHOULD BE THE DOSE WHICH IS ACCEPTABLE FOR GENERAL POPULATION EX-
POSURE. IN A LOS ALAMOS SCIENTIFIC LABORATORY REPORT DATED JANUARY, 1974, J. W.
HEALY PUBLISHED "A PROPOSED INTERIM STANDARD FOR PLUTONIUM IN SOILS". AS A RESULT
OF THE AUTHOR'S INVESTIGATION, A SOIL CONTAMINATION STANDARD OF 500 DISINTEGRATIONS
PER MINUTE PER GRAM OF DRY SOIL IS PROPOSED AND IS BASED UPON THE DELIVERANCE
OF THE MAXIMUM PERMISSIBLE DOSE TO A SIZEABLE PORTION OF GENERAL POPULATION.
THE MAXIMUM PERMISSIBLE DOSE TO THE GENERAL POPULATION IS FOR EXPOSURES FROM
ALL SOURCES AND NOT PLUTONIUM-IN-SOIL ALONE, AND THEREFORE ITS USE IS
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UNACCEPTABLE.
AS A JUSTIFICATION FOR THE THEN PROPOSED COLORADO STANDARD, AN EXAMPLE OF A
REASONABLE SCALING DOWN OF AN OCCUPATIONAL EXPOSURE TO LEVELS FOR EXPOSURES OF
GENERAL POPULATIONS WAS PROVIDED; IF A CONTAMINATION LEVEL OF 300 DISINTEGRA-
TIONS PER MINUTE OF PLUTONIUM PER SQUARE CENTIMETER OF SURFACE AREA IS APPROPRI-
ATE FOR AN OCCUPATIONAL EXPOSURE, CONSISTENT WITH THE MAXIMUM DOSE TO THE
CRITICAL ORGAN OF 15 REMS PER YEAR, (FOR INSOLUBLE PLUTONIUM), AN ACCEPTABLE
LIMIT FOR A GENERAL POPULATION WOULD BE 0.3 DISINTEGRATIONS PER MINUTE PER
GRAM OF DRY SOIL BASED ON 1 GRAM PER CUBIC CENTIMETER AS THE SOIL DENSITY AND A
SAMPLING DEPTH OF 1 CENTIMETER. THE REDUCTION FACTOR OF 1000 WOULD REDUCE THE
ORGAN DOSE WELL BELOW THAT IDENTIFIED BY NATIONAL AND INTERNATIONAL GROUPS AS
THE MAXIMUM PERMISSIBLE DOSE FOR LARGE SEGMENTS OF THE GENERAL POPULATION. SUCH
A FACTOR (1000) IS USED BY LICENSING AGENCIES IN THE REGULATION OF MANUFACTURE
OF GAS AND AEROSOL DETECTORS USING RADIOACTIVE MATERIAL (PRIMARILY AMERICIUM 241)
AND THEIR DISTRIBUTION TO PERSONS EXEMPT FROM REGULATORY CONTROL (TITLE 10, CODE
OF FEDERAL REGULATIONS 32.27).
AS A RESULT OF PUBLIC HEARINGS ON FEBRUARY 14 AND MARCH 21, 1973, BEFORE THE
SIATE BOARD OF HEALTH, THE DEPARTMENT'S RULE MAKING BODY, DURING WHICH TESTIMONY
WAS PRESENTED BY SPOKESMAN FOR FEDERAL, STATE AND LOCAL GOVERNMENTS, INDUSTRY,
AND ENVIRONMENTAL ORGANIZATIONS, AND BY "CONCERNED CITIZENS", AND LAND OWNER
REPRESENTATIVES, THE BOARD OF HEALTH ADOPTED A STANDARD OF 2 DISINTEGRATIONS PER
MINUTE PER GRAM OF DRY SOIL. THE ACTUAL WORDING OF THE COLORADO STANDARD IS AS
FOLLOWS: "PERMISSIBLE LEVELS OF RADIOACTIVITY IN UNCONTROLLED AREAS. PLUTONIUM.
CONTAMINATION OF THE SOIL IN EXCESS OF 2 DISINTEGRATIONS PER MINUTE OF PLUTONIUM
PER GRAM OF DRY SOIL OR SQUARE CENTIMETER OF SURFACE AREA (0.01 MICRO-CURIES OF
PLUTONIUM PER SQUARE METER) PRESENTS A SUFFICIENT HAZARD TO THE PUBLIC HEALTH TO
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REQUIRE HIE UTILIZATION OF SPECIAL TECHNIQUES OF CONSTRUCTION UPON THE PROPERTY
SO CONTAMINATED. EVALUATION OF PROPOSED CONTROL TECHNIQUES SHALL BE AVAILABLE
FROM THE DEPARTMENT OF HEALTH UPON REQUEST." THIS STANDARD WAS NOT ADOPTED
UPON EXTENSIVE TECHNICAL AND CONCLUSIVE EVIDENCE WHICH WAS LACKING, BUT UPON
THE JUDGMENT THAT REASONABLE CONSERVATISM WAS NECESSARY AT THIS POINT IN TIME
AND REALIZING THAT OTHER TRANSURANIC MATERIAL ALSO WAS ASSOCIATED WITH THE
PLUTONIUM SOIL CONTAMINATION. THE STANDARD ALSO SERVES AS A CAUTION TO DEVELOP-
MENT, PLANNING AND PLATTING AGENCIES OF THE NEED FOR PROPER LAND-USE PLANNING
DUE TO THE PUBLIC HEALTH HAZARD POTENTIAL PRESENTED BY THE PLANT'S EXISTANCE.
IT IS ANTICIPATED THAT SUBDIVIDED LAND HAVING SOIL CONCENTRATION APPROXIMATING
THIS STANDARD WOULD NOT EXPERIENCE AIR- CONCENTRATIONS SIGNIFICANTLY DIFFERENT
THAN THOSE OBSERVED DUE TO WORLD-WIDE FALLOUT.
SINCE THE ADOPTION OF THE ABOVE PLUTONIUM-IN-SOIL STANDARD, THE COOPERATION
OF THE AGENCIES, DEVELOPERS, AND OTHERS HAS ALLOWED ORDERLY APPLICATION OF THAT
STANDARD.
BECAUSE THE STATE OF COLORADO HAS HAD CONSIDERABLE EXPERIENCE REGARDING
LUNG EXPOSURE BY OTHER ALPHA EMITTERS, SPECIFICALLY RADON DAUGHTER EXPOSURES OF
URANIUM MINERS AND THE ADOPTION OF ADEQUATE PROTECTION STANDARDS FOR THESE
INDIVIDUALS, THE DEPARTMENT FEELS THAT THE BODY OF PLUTONIUM-IN-MAN DATA IS
NOT SUFFICIENT AT THIS TIME TO ESTABLISH STANDARDS WHOLLY BASED ON THE BIOLOGICAL
EFFECTS FROM PLUTONIUM OBSERVED TO DATE. THE LATENT PERIOD TO OBSERVE THE
EFFECTS OF THIS MATERIAL WITHIN THE BODY IS SUCH THAT ONLY TRULY CONSERVATIVE
STANDARDS CAN BE SET FOR PLUTONIUM WHEN A LARGE SEGMENT OF THE GENERAL POPULA-
TION IS AT RISK.
THE AEC HAS SET IN MOTION PROCEDURES TO ACQUIRE ADDITIONAL LAND SURROUNDING
THE PLANT SITE AS A BUFFER AREA. THE ACQUISITION OF THIS LAND WILL PRECLUDE THE
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USE OF LAND CONTAMINATED SIGNIFICANTLY IN EXCESS OF THE STANDARDS ADOPTED BY
COLORADO. THE PRESENT DISTRIBUTION OF PLUTONIUM IN SOILS GIVES US INSIGHT AS
TO THE LONG TERM RELEASE OF PLUTONIUM FROM DAILY OPERATIONS AND IN ANY INCIDENT
WHICH MIGHT OCCUR. ANY DISTRIBUTION OR REDISTRIBUTION WILL ESSENTIALLY BE IN
THIS SAME PATTERN. HOPEFULLY PROGRESSIVE AND AGGRESSIVE MANAGEMENT ACTIONS BY
BOTH THE AEG AND ITS CONTRACTOR WOULD PRECLUDE THE RELEASE OF ANY ADDITIONAL
SIGNIFICANT INVENTORIES OF RADIOACTIVE MATERIAL FROM THE PLANT TO ITS ENVIRONS.
A MAJOR INCIDENT RELEASING SIGNIFICANT QUANTITIES OF MATERIAL TO THE OFFSITE
ENVIRONS COULD DRASTICALLY CHANGE THE CONCENTRATIONS IN SOIL WHICH ARE PRESENTLY
BEING OBSERVED, AND THEREFORE, MAKE ALL EFFORTS IN REGARD TO PROPER REZONING
USING THE COLORADO STANDARD INVALID.
THE DATA AND INFORMATION PRESENTED IN THIS STATEMENT NATURALLY EMPHASIZED
AIR AND SOIL PARAMETERS. THE DEPARTMENT HAS ACQUIRED CONSIDERABLE DATA ON
SURFACE WATERS AND POTABLE WATER SUPPLIES IN THE DENVER METROPOLITAN AREA.
ADDITIONALLY, EPA HAS ASSISTED THE STATE IN DETERMINING THE BUILDUP OF
PLUTONIUM IN A NUMBER OF RAW WATER RESERVOIRS IN THE AREA. OUR INFORMATION
AND DATA ARE AVAILABLE FOR YOUR PERUSAL AND USE.
THE DEPARTMENT WISHES TO EXPRESS ITS APPRECIATION FOR THE BRINGING OF
THESE HEARINGS TO THE DENVER AREA AND THE PRIVILEGE OF MAKING A PRESENTATION.
AGAIN, WE WOULD REQUEST THAT ANY STANDARDS REGARDING EXPOSURE OF THE GENERAL
PUBLIC BE OF NECESSITY TRULY CONSERVATIVE.
THANK YOU.
1/8/75
AJH/pc
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SUGGESTED INTERIM GUIDANCE
for
EVALUATION (tlov. 1972)
required under Chapter 106, CRS 1963, as amended
(106-2-34 (3)(a) and 106-2-34(3)(c)(iv)
To assist the Board of County Coiraru ssioners in fulfilling the requirements
of the Act, the following is provided by the Colorado Department of Health.
I. Information to be provided in the required evaluation:
A. Prior land use history of proposed plat
1. Specify for the proposed plat and any portion thereof, the different
land use histories in relation to solid disturbance.
a. Situations to be considered
(1) Virgin or undisturbed ground
(2) Disturbed ground (specify depth of disturbance)
(a) Single (date)
(b) Routine
((!)) Yearly
((a)) Contour Plovzing
((b)) Strip Plowing
((2)) Others (specify)
(c) Others (specify)
B. Method of taking representative samples
1, Detailed description of sample acquisition and its justification
in relation to hazard analysis.
a. Items to be considered (but not limited to)
(1) Depth of sample
(a) Disturbed soil situation
(b) Undisturbed soil situation
(2) Involved surface area of indivudal sample
(3) Number of samples taken per unit land area
(a) .Increase or decrease number due to
((!)) Different land forms
((2)) Water bodies and streams
C. Method of Analysis
1. Describe in detail, or if documented procedure, reference the
procedure and qualify any changes in that referenced procedure.
2. Specify quality control procedures for the analytical procedure
• employed.
a. Number of analyses per sample (replicates)
b. Participation in inter-laboratory cross-check programs
(AEG or EPA)
c. Standards traceable to nationally recognized source
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D. Evaluation
1. Results of analyses to be presented by table and map with
specific sampling sites and land use histories identified.
2. Methods for "averaging" and handling anomalous data specified.
3. Criteria or guidelines used in the hazard evaluation specifically
described or referenced.
4. Specify all^ assumptions used and qualify their use.
5. Specify appropriate methods for control of the radiation hazard.
6. Specify the name and qualifications of the individual performing
the radiation hazard evaluation.
II. A. Prior to a subdivider, or an agent for a subdivides performing or
causing to perform the required evaluation, the information required
under Item I, v?ith exception of I. D. 1. and I. D. 5., shall
be submitted to the Board of County Commissioners for reviev/ and conunent.
B. The Colorado Department of Health shall assist the Board of County
Commissioners in their reviev? of the proposed evaluation. Upon
approval as appropriate to fulfill the requirements of the Act,
ihe evaluation may proceed.
III. Upon completion of the required evaluation and submission to the Board
of County Commissioners, the Colorado Department of Health shall assist
the Board in its deliberations as to the efficacy or the proposed land
'use in relation to the radiation hazard identified. Disposition of
this matter nay take various forms:
A. Unqualified approval
B. Qualified approval
C. Postponed or deferred decision (taken under advisement)
D. Disapproval or rejection.
IV. Areas of Concern (Specific for each county)
A. General areas of natural deposits of uranium and/or thorium
1. Locations identified by the U. S. Geological Survey as possessing
significant quantities and concentrations or as otherwise
identified.
B. General areas surrounding nuclear facilities •
1. Production and/or utilization -facilities, as defined by U. S.
A.E.G. regulations.
2L. Uranium and thorium raill towns.
3. Areas as otherwise identified.
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Thank you.
Chairman Mills: Thank you, Mr. Hazle. Most of us are
well aware of the considerable effort that the State of
Colorado has put into the detection of plutonium, and I
commend the Health Department in this regard.
In your monitoring followup, have you found any
appreciable change in the movement of the plutonium in the
soil?
Mr. Hazle: There is before the Board of County Com-
missioners a parcel of land which is in excess of two, and
there were proposed to ha,ve techniques used, namely plowing
in this particular circumstance. Action has not been taken
by the County Commissioners, therefore there has been no
change in that land.
Chairman Mills: What my question referred to, in doing
your sampling, you have been sampling I think in the first
eighth of an inch?
Mr. Hazle: That is correct.
Chairman Mills: Have you seen any movement of the
plutonium down in the soil? I am raising the question from
the standpoint that there is concern that resuspension of
plutonium in soil, any resuspension numbers used should be
different from fresh plutonium deposits as opposed to that
which might have been aged somewhat.
Mr. Hazle: The information which we have seen does not
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198
really shqw, because of the statistics involved, the gross
movement of the plutonium downwind. The resuspension terms,
which we generated realizing the accuracy of these terms,
a
approximate 1x10" per meter. The air concentration half-
times which we are observing, now realizing full well when
we started observing this, the plutonium was already aged in
the soil because the leakage from the storge material which
was stored from 1957 to approximately 1968, and we started
sampling in 1970. So, you already have aged plutonium in
the soil. But the air concentration half-times which we are
seeing, and subtracting out the worldwide fallout which has
also a half-time, we see approximately 2.7 years air con-
centration at this occurrence rate, if you will.
Chairman Mills: One other question. Your background
level I guess in the determination of your .2 disintegrations
per minute per gram of soil, you basically doubled the .08.
You mentioned this as an average concentration --
Mr. Hazle: Right.
Chairman Mills: Could you give us some indication of
what the range is, not just the average?
Mr. Hazle: The range really did not vary very much, as
I remember. I think it went from .11 down to .04 or .06.
Is that correct, Bel? (Belmont S. Evans - nodded concur-
rence .)
Chairman Mills: Any question by the Panel?
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199
Dr. Morgan: Dr. Hazle, you indicated that the vehicular
traffic and excavation resulted in instantaneous concentra-
tions that would be in excess of maximum permissible concen-
trations for large segments of the population by several
orders of magnitude. You are saying then, I would assume
this by factors of thousands or tens of thousands to make it
several orders of magnitude, but that this would be in the
restricted areas and would not apply to the offsite situa-
tion. Since these levels were quite high, I would assume
that even further out there are people living near highways
or industrial areas, and they might have fairly large
concentrations as a consequence; and then later you indicated
that the purchase of this land extending the area under
control would mean that these levels would not exceed those
adopted by Colorado.
Mr. Hazle: That is correct.
Dr. Morgan: I would ask you, then, was this the reason
for the purchase of this additional land, because there
were areas then that exceed the levels of adopted by Colorado?
Mr. Hazle: Going back to the area around the oil spill
which is the source of the contamination offsite, we have
samplers which run there continuously. Day-long integrated
samples are now changing to every other day. We have seen
concentrations which go up to .4 picocurie per cubic meter
of air when we do have vehicular traffic or when they are
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200
doing excavation to lay tie lines. Those have been observed.
But, these are integrated samples going through a nighttime
period when there would not be any real concentration of
material, it would be resuspended. My statement regarding
many orders of magnitude is regarding an adjustment state-
ment that an integration would dilute the concentration.
Dr. Morgan: But this land that was recently purchased
or added to the site, were the levels there above the
Colorado standard?
Mr. Hazle: Yes, sir, the concentrations which are
experienced and which have been identified by a number of
groups, these would go up into the hundred or two hundred
disintegrations per minute per gram.
Dr. Morgan: One other question, I believe you indicated
that Wright Langham's resuspension factor of 7X1CT4, whereas
in some other cases values as high as 10~3 have been used.
What does your data seem to indicate as a reasonable factor
for resuspension factor for dry soils?
Mr. Hazle: What we have experienced based on a yearly
average is IxlCT9 per meter.
Dr. Morgan: This would include the wet conditions as
well as dry?
Mr. Hazle: That is correct, and we do see during the
later stages of summer and the first of fall, which normally
is our dry time, an increase of air concentrations over the
contaminated soil areas.
-------
Dr. Morgan: What would be an average for dry conditions?
Mr. Hazle: I have not calculated that out, sir. Also,
thank you for the Doctor, I am not a Doctor.
Chairman Mills: Dr. Taylor has a question.
Dr. Taylor: I found this a very interesting presen-
tation, and I am going to study it more so my question may
have been answered, and I may have missed the point. I
believe that the standards which you have arrived at which
you consider acceptable here are basically derived from
those worked out by the NCRP and ICRP Tripartite Conferences
for Occupational Exposure and for Population Exposures.
Mr. Hazle: I am afraid not, sir. We essentially took
the background information and said this is a little bit
ultraconservative, and a reasonable adjustment of those
figures because the number would be completely arbitrary
down that low, the reasonable adjustment up to a level which
the likelihood of getting concentrations in excess of world-
wide fallout would be approximately two, and so the two (2
dpm/g) was the number grabbed out of the air, in all
practicality.
Dr. Taylor: This was related back as being substan-
tially smaller than the international ones?
Mr. Hazle: Yes.
Dr. Taylor: There have been, of course, no observed
effects of international or on the NCRP or ICRP standards,
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and obviously no observed effects of any kind on your
particular standards. This is correct, is it not?
Mr. Hazle: As far as the occupational exposures to
date, there has been no observalbe effects.
Dr. Taylor: That is your understanding also?
Mr. Hazel: That is correct.
Dr. Taylor: I just wanted to be sure that this was
then a matter of largely judgment and is not based on any
technical findings we know of as yet.
Mr. Hazle: That is correct. Truly a conservative
approach, sir.
Dr. Taylor: Thank you.
Dr. Snyder: I would like to direct a comment really
just to get your response to it. It is for reasons of this
kind that the ICRP has adopted a different term than the
maximum permisssible dose in connection with exposure of
population. Because your standard is based on a an existing
situation which is not controllable by us or this country,
and therefore it may need to be changed in the future. Of
course, it can be changed as it has to be. But, I just
point out that they, therefore, discourage the use of this
term in this connection.
Dr. Taylor: You are referring to the use of the term
"dose limit"?
Dr. Snyder: That is correct.
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203
Mr. Hazle: If I might comment a little further, most
of these people who have done those kinds of calculations
have used those particular terms and have used factored-down
situations, but have not used the recent recommendations of
NCRP using the somatic dose of 170 milligrams per year.
Chairman Mills: Mr. Hazle, for the completeness of the
record, I wonder if you would add to the record your complete
citation of the references that you used, Dr. Langham and
Mr. Healy, and so forth?
Mr. Hazle: I will send that information to you, and
additionally I would like to comment that we have provided
the suggested interim guidance which was provided to the
County Commissioners and the people involved. (Note: the
references are included in the section on additional material
submitted for the hearing record.) (Volume 3)
Chairman Mills: That would be part of the record.
Thank you very much.
Dr. Mills: The next speaker represents the City of
Boulder. Are you Ms. Correll?
Ms. Correll: Yes. I am Ruth Correll, member of the
City Council of Boulder.
Members of the Board, Ladies and Gentlemen:
The City of Boulder appreciates this opportunity to
address the United States Environmental Protection Agency on
a matter of concern to our citizens and their political
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204
leaders. Our statement is brief because it is our desire to
focus your attention on the two issues of primary concern to
us.
As we attempt to assess the effects of a plutonium
processing facility located only ten miles from our city
limits, we are faced with the question of the results of
prolonged exposure to low levels of radiation --a question
which, given the current level of technical and scientific
knowledge, is, as you know, difficult to answer. Yet, it is
imperative that the political leaders charged with pro-
tecting the health and safety of our citizens be able to
determine three things: (1) what is an acceptable level of
exposure to plutonium radiation? (2) to what level is the
community of Boulder and Metro Denver now exposed, and (3)
what are the definable and possible consequences of that
exposure? The responsibility for that determination falls
most heavily, we think, on the Federal Government, which is
ultimately responsible for the existence of any potential
hazard.
The necessary scientific investigations to answer these
questions are well beyond the financial and jurisdictional
scope of the City of Boulder. Therefore, we request that
the Environmental Protection Agency insure that studies to
answer these questions and to define the effects of pro-
longed exposure to low levels of radiation be made and that
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205
those reports and those investigations be given fully to the
public. We emphasize our willingness as a city to partici-
pate with other agencies to carry out these vital studies.
The work which has to be performed is highly technical.
It requires a great deal of skill and experience in the area
of health physics. It is important that we build on previous
research.
Our second concern as a city is the lack of public
input in past decisions regarding such important factors as
the location of nuclear processing facilities; the establish-
ment of radiation protection standards, nuclear employee job
safety protection; the responsibility for emergency services
in case of a major disaster; and whether the city itself has
some responsibility. We are concerned about any other
issues which may have a direct bearing on our city and its
citizens. Hopefully today's hearings are only the first in
a new era of openness and public participation in these
kinds of decisions. We trust that they do signal a new
attitude of cooperation between local citizens and their
governments and the Federal agencies, such as the Atomic
Energy Commission, who are responsible for the decisions.
A factor in determining how much risk citizens are
willing to accept is the planning for development of
alternative energy sources, and we believe it is important
for the EPA and other Federal agencies to unite in the
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206
support of research in the development of additional energy
options.
Again, on behalf of our citizens of Boulder, we thank
you for this opportunity to present our concerns to you and
we look forward to the decisions and the actions which you
will take in our behalf and in behalf of the citizens of
Colorado.
Chairman Mills: Thank you very much, Ms. Correll. Are
there any questions? Dr. Morgan?
Dr. Morgan: You indicated that the distance was about
ten miles from the city limits. Is this ten miles from the
boundary of Rocky Flats, or is it ten miles to the nearest
operating facility?
Ms. Correll: Are you talking about the center --
Dr. Morgan: From the city limits of Boulder, is the
distance ten miles to the nearest operating facility or to
the fence boundary?
Ms. Correll: As far as I know, it is the distance to
the operating facility. I have not actually measured that.
Dr. Morgan: You mentioned some concern about emergency
plans. Do you in the City of Boulder have emergency plans
which have been coordinated with the Rocky Flats operations
personnel?
Ms. Correll: No, we have not, and this is one of our
concerns. Is a city, any city in the area, somewhat
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207
responsibile in case there were a major disaster, and should
we be informed and aware of what our responsibility might
be? It does make a great deal of difference.
Chairman Mills: In that regard, have you worked any
with the State Health Department in this regard for pro-
tection action guides or emergency action guides?
Ms. Correll: We have what I would call the standard
provisions for disasters. They have not been particularly
coordinated in relation to a nuclear disaster; and one of
our concerns is the fact that as the population thickens
around the plant, we might perhaps need to do this. Does
this then indicate an expenditure of local funds for this
kind of coordination, or what is our burden, and what is the
burden actually of other cities?
Chairman Mills: I think you have emphasized that it
does need a great deal of cooperation between the Federal
Government and the states and local government.
Thank you very much.
The next speaker is Dr. Carl Johnson, the Health Officer
for Jefferson County, Colorado.
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208
MEMORANDUM
TO: Director, Criteria and Standards Division
Office of Radiation Programs
United States Environmental Protection Agency
Washington, D.C. 20460
FROM: Carl J. Johnson, M.D.
Director of Health
Jefferson County Health Department
260 S. Kipling Street
Lakewood, Colorado 80226
RE: Public Hearing Concerning Plutonium and
the Transuranium Elements, on January 10,
1975 in the Denver Post Office Building,
Denver, Colorado
There is an urgent need for the establishment of maximum permissable levels of con-
tamination of soil by Plutonium. In Jefferson County there is a plan to develop for resident-
ial use, land nearly a square mile' in area downwind from the Rocky Flats facility of the Dow
Chemical Company. The degree of contamination of the soil by Plutonium in this area has
been evaluated and has been found to range as high as 560 times the background level for
Colorado, which is 0.08 discharges per minute per gram of dry top soil (DPM/gram). There
is an area approximately one and one-half miles upwind which reportedly has soil contam-
ination ranging as high as 20,000 DPM per gram, or about 250,000 times the background
level. The general area is dry and dusty and noted for strong winds ranging up to 80 miles
per hour and higher.
The table below contains estimates of the dimensions and the area of the land that is
contaminated, from a map illustrating Plutonium 239 accumulation in soils surrounding the
Rocky Flats plant ( U.S.A.E.G. Report HASL-235 (1970)].
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Plutonium 239 - page two
209
Table 1
Estimated dimensions and area of land contaminated with Plutonium 239 around the Rocky Flats
facility, by amount of contamination expressed in disintegrations per minute per gram of dry
topsoil, and compared to the background level for Colorado"'.
Contamination with
Plutonium 239 in
disintegrations/min/
gram of dry topsoil
20,000
8,000
> 440
> 110
> 11
> 4.4
> 2.2
> 1.1
> 0.6
Contamination with
Plutonium 239 in
relation to typical
background levels
for Colorado
250,000 x
100,000 x
> 5,500 x
> l,400x
> 140 x
> 55 x
> 27 x
> 14 x
> 7x
Approximate dimensions
of area of contamination
in miles
-
-
1/3 x 1/2
0.6 x 1
1 x 2.7
1.5 x 3.5
4x6
5x7
7x8
Estimated area
contaminated in
square miles
-
-
0.14
0.5
2.5
4.9
20
28
44
(1) Estimated from P.W. IKrey and E.P. Hardy, Plutonium in soil around the Rocky Flats
plant, USAEC Report HASL - 235 (1970)
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Plutonium 239 - page three
Subsequent maps showing the extent of plutonium contamination indicate that a smaller
area is involved, or that significant dispersion has occurred.
Because of interest in developing land near the Rocky Flats facility, the Colorado State
Health Department was requested to establish temporary maximum permissable levels of
plutonium contamination in 1973. The maximum permissable level was recommended to be
0.2 DPM/gram of dry top-soij^or 2 1/2 times the background level. Where this level was
exceeded, construction for residential purposes was not to be permitted. 1 believe that these
recommendations reflected the best judgement of the State Health Department personnel who
were trained in the field of radiological health. However, because this level was felt to be
unduly restrictive, the State Board of Health set the official maximum allowable level at
2.0 DP/vVgram or about 25 times the background level. In addition, residential construction
could be permitted where plutonium contamination was in excess of these levels, if State
guidelines for treatment of the soil were followed to reduce levels of contamination.
However, such treatment of soil (plowing or removal of top-soil), does not prevent
subsequent recontamination of the area by dust blown from adjoining lands, after the area
has been developed for residential use. In addition, since accidental releases of radio-
active material have occurred on several occasions, it does not seem possible to rule out
subsequent accidental releases of radioactive material, recontaminating areas that have
been so treated.
We do not appear to have sufficient information about long-term effects resulting
from exposure to plutonium to establish definitive standards. However, interim standards
are essential If large numbers of people are to be protected from unnecessary exposure to
plutonium. Past experience with standards for maximum permissable exposures or doseages
established for radioactive materials indicates that a very high safety factor should be con-
-------
Plutonium 239 - page four oil
& Jl *
sidered where there is Insufficient information about the long-term effects of exposure.
There is considerable data available concerning the toxicity of plutonium for ex-
perimental animals and there is some data relative to the meaning of industrial exposures
for human adults (usually 40 hours weekly for a period of several years or more). However,
I do not believe any work has been done to demonstrate the hazards of continuous exposure
to low levels of plutonium for the developing fetus or child. This portion of the population
is most susceptable to damage to chromosomes and genetic injury, and exposure to increased
levels of radiation will result in an increase in the incidence of developmental defects at
••,
birth and neoplasms in later life.
A generous safety factor is allowed when considering the maximum allowable con-
centration of hazardous chemical substances to which one may be exposed without risk
of injury. Because of the insidious nature and long-delayed effects of exposure to radio-
active substances, a safety factor many orders greater should be accepted, especially for
situations'in which the most susceptable part of me population will be subjected to a continuous
exposure for many years, as in a residential development. In considering acceptable levels
of exposure to radiation in a residential setting, it is much better to err on the side of caution.
For these reasons I urge the Environmental Protection Agency to establish maximum per-
missable levels for plutonium contamination of soil in areas that are to be used for residential
purposes. I recommend that these maximum permissable levels include a safety factor many
orders greater than that accepted for exposure to hazardous chemical substances.
Dr. Johnson: An additional point I wanted to make is
that where an area is developed and you have paved surfaces,
I think the resuspension factor would be much larger than
that for soil.
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21
PLUTONIUM-239 AND AMERICIUM-241 CONTAMINATION IN THE DENVER
Plutonium levels expressed in disintegrations per minute per gram of dry topsoil
(1) Poet, S.E. and Kartell, E.A.: Plutonium-239 and Americium-241
contamination in the Denver area Health Phys. 23:537-548 Oct., 1972
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213
Chairman Mills: Thank you, Dr. Johnson. I wonder if
you could clarify for me, expand on your last statement,
that is, "I recommend that these maximum permissible levels
include a safety factor many orders greater than that accepted
for exposure to hazardous chemical substances." Would you
expand on that? I assume you are talking about not any
chemical toxicity associated with the radioactive material,
but nonradiating emitting substances?
Dr. Johnson: Yes, I think there is a fundamental
difference between the two types of hazards. The hazard
from a chemical such as carbontetrachloride can be easily
evaluated by doing tests on liver function, and then you can
enter an appropriate safety factor to bar hazard from
industrial exposure. Now, for hazardous substances such as
plutonium (which I understand is fifteen times more hazard-
ous than radium) as with any other radioactive element, the
effects may not be fully experienced for 30 years or perhaps
longer. In fact, the effects induced by exposure to radia-
tion are quite difficult to estimate.
Chairman Mills: Dr. Taylor has a question.
Dr. Taylor: I am interested in that same point that
you have brought out and would point out that in the case of
some chemical substances, I am not sure I could name them at
the moment, you also have long latent periods of effect
showing after the injury.
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214
I wanted to ask about the statement in the last page,
"...considerable data available concerning the toxicity of
plutoniura for experimental animals..." This, of course, is
quite true but extremely large doses compared to any amounts
that we are concerned with in the general environment.
Also, "...some data relative to the meaning of industrial
exposures for human adults...," and there I believe it can
be said quite safely that there has been no identifiable
injury to radiation workers containing body burdens of
plutonium that are within the standards, whatever you want
to call them, maximum permissible dose limits. I do not see
how you can expect any possibility as you sort of imply here
of demonstrating effects at much lower levels than these.
These have been studied for many, many years. Hundreds of
millions of dollars have been spent on trying to find low-
level effects of radiation. So far largely -- well, I would
not say largely, I would say entirely without success at the
sort of background levels that we are talking about.
Dr. Johnson: I really feel the sort of information we
need can be gotten from a large scale epidemiological eval-
uation of the lifetime experience of people who have had
these occupational exposures, looking for significant
increases in the incidence of neoplasms of various types.
We should also study the offspring, including the second and
third generations, looking for significant changes in the
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215
frequency of developmental defects.
Dr. Taylor: There are such studies that have been in
progress for years now. The Mancusso Study is an example
where so far at levels much higher than we are talking about
in this environment today have been, I believe, unproductive
in showing anything definitive. Now, if you get down to
exposures which are still even lower, I gather from your
remarks, than the fetal exposures and so on, I just do not
think there is any practical likelihood of this being
accomplished in the many lifetimes that are ahead of any of
us here today. This is not to say, do not do something about
it, but do not kid yourselves into thinking that you are
going to get some tangible biomedical evidence that will
stir you on this.
Dr. Johnson: I guess that all I really want is some
definite standards established which can be identified as
interim standards, that can be enforced, in order to limit
development of land for residential use in the areas where
significant levels of plutonium are found, and so prevent
any unforeseen effects. We do have some indication from
experience with radiation for diagnostic and therapeutic
purposes of pregnant women that exposure to ionizing radia-
tion is not good. I think we can extrapolate from that and
say that a safety factor many orders larger than that for an
occupational setting is required for a residential environ-
-------
ment. That is really all I want, some standards which
reflect a very large order of safety.
Dr. First: We had some information from the people at
Rocky Flats a little earlier to the effect that the environ-
mental measurements over the past several years, I believe
they said, were less than 1%, considerably less than II in
most cases of the currently-established standards. I wonder
why the concern with establishing standards for soil con-
tamination when the effects of this have not been measured
in spite of the high numbers which you have cited. What is
the connection, have you made a connection between soil
contamination and the exposure of people?
Dr. Johnson: Well, of course, I have not conducted any
studies myself. I am speaking as a Health Officer for
Jefferson County. I do think dust quite often is resuspended
in this area. It is a rather dry area. There are strong,
gusty winds at intervals which blow dust about. If the area
is developed and there are paved streets and sidewalks, the
dust which is subsequently redeposited on these paved sur-
faces are much more likely to be resuspended and inhaled.
In addition, I think we will have dust drifting inside
homes, and once you have dust inside a house, as you know,
it is going to be resuspended almost daily by vacuum
cleaners.
Dr. First: Do you dispute in any way the information
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217
that the Rocky Flats people have presented to us that the
measurements in the communities and at the boundary line of
the plant itself have consistently been less than 1% of the
current standard?
Dr. Johnson: I am not aware of what the current
standard is. In fact, I wonder if there is such a standard,
and if such a standard really is realistic or adequate.
Dr First: Well, the measurements currently are at
least two orders of magnitude below the current standard.
Would you not say that provides a safety factor of some
degree and that the establishment of standards for soil
contamination is not responsive to the problems that we are
facing, namely, human exposure over long periods? I do not
understand how you get from soil contamination to a danger
to populations when the measurements show that the levels
are close to background or are at background. Can you
explain that to me?
Dr. Johnson: I have just tried to illustrate using
data generated by the Atomic Energy Commission that the
levels of plutonium in this area are much in excess of
background levels for plutonium.
Dr. First: In the air?
Dr. Johnson: This refers to the soil. I think the
very fact that we have seen that plutonium has moved from
the original site on the Rocky Flats facility downwind for,
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218
I believe, a total distance of five or six miles or more
constitutes evidence that the material is suspended in the
air, and could be inhaled or find itself inside a home if
construction were permitted in this area.
Dr. First: It is your conclusion then that the mere
fact that there is plutonium in the soil regardless of what
its subsequent fate is is a danger to the population; it
that correct?
Dr. Johnson: Yes, I do think the topsoil can be
resuspended in the air and be inhaled.
Dr. First: But, it has not been so demonstrated?
Dr. Johnson: There is a study with dairy cattle which
I do not think has been officially released. Some feel that
hazards have been overstated. I think what the study does
demonstrate is that cattle can inhale this dust into the
lungs, and I think that humans can too. (Note added: I
have since learned that this study herd came from north of
the Rocky Flats Plant, and was exposed to much lower amounts
of plutonium than is present downwind, to the east and
southeast.)
Dr. First: Mr. Chairman, if it is permitted, and this
is at your discretion, I would like to turn this question
over to the people who gave us the information from Rocky
Flats to get their response to this point.
Chairman Mills: Mr. Bean, are you here? Do you have
any comment to make, Mr. Bean?
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219
Mr. Bean: Why don't I take the microphone.
(Whereupon, Mr. Bean came to the microphone.)
Mr. Bean: Would you make the point specifically? Is
it the cattle or the air that you are concerned with?
Dr. First: I am concerned with the question of the
connection between the contamination of soil, which I assume
you do not dispute the figures that have been produced as
cited by Hazle, and the measurements that you people have
made over the past several years showing these very low con-
centrations in the environment which you have cited, and the
thing that worries me is what is the connection between the
two in terms of human exposures? Is this a danger? The
Doctor has said that he is quite concerned about it. I
wonder what your attitude is about this?
Mr. Bean: Number one, let me talk about the way the
plutonium got there. The plutonium was spilled from these
oil drums on the ground. Now, since that time the area where
the plutonium was spilled was covered with an asphalt pad.
The plutonium is fixed under the pad. So, the original
source material has been eliminated. It is not there any
more. Plutonium was distributed downwind during the time
the oil drums were there. So, the source material is much
different today than it was then. That is number one.
The air sampling results that we see are, as we said
before, less than 1% of the standard, and our air sampling
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220
results can be verified by the Colorado Department of Health
who do the same kind of air sampling in communities and
around the plant, and we do not see the relationship between
the soil and the air.
Dr. First: You are not worried about this as is the
Health Commissioner, I take it?
Mr. Bean: I would not say that we are not concerned
about the soil and the contamination of the air. I think
our job is to assure that there is no further, no additional
material added to the soil that would create another problem.
Dr. First: Would you not advocate, or would you, that
the soil is suitable for development in the ways which have
been discussed?
Mr. Bean: I think the AEC has previously testified at
the original hearings with the Colorado Department of Health
that their standard of .2 of a DPM per gram was unduly
restrictive.
Dr. First: Thank you.
Dr. Garner: I want to resist very strongly the
suggestion that is being made that we apply different kinds
of value judgments to the development of standards for
radioactive material and for chemical substances. The
implication here is that we know a great deal more about the
biological effects of chemical substances than we do of
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221
radioactive materials. Whereas, the converse is true, as I
think any of us who have been involved with radioactive
materials know very well. One particular substance was
mentioned, carbontetrachloride. It was said that it was
very easy to establish the biological effects of carbon-
tetrachloride on the basis of liver function tests and so
forth. It is perfectly true that one can establish the
short-term effects of carbontetrachloride very easily.
Equally true that one can establish the effects of radio-
active material very easily. But, it is just as difficult
to establish the long-term effects of carbontetrachloride
which is a carcinogent just like plutonium. It is just as
difficult to establish the long-term effects of carbon-
tetrachloride as it is of plutonium. In fact, we know very
little indeed, very little of the long-term effects of many
chemical environmental pollutants, and therefore I would
suggest that if we are going to apply conservative safety
factors, we apply them all around, not just to radioactive
materials, but also to other chemical carcinogents in the
environment.
Dr. Snyder: I would like to comment, if I may, that in
the AEC's testimony they did present evidence on some pla-
cental discrimination, so that the question of the fetus and
the child have not been ignored completely. However, I would
not pretend that this answer all possible questions, but
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222
still there has been some study of this question; and
second, I would agree with the last speaker that I think we
have a handle on radioactivity through the dose concept that
we do not have with carbontetrachloride or practically any
other chemical pollutant, and therefore we would not be well
advised to use that as our standard. By the same standard
for radioactivity, then, the occupational levels would be of
no concern because no effects have been found in the people
at and above these levels, and so presumably then we would
say they are harmless. But, we do not quite buy that
philosophy because we feel that there is some probability
these people have not lived out their lives yet and there is
perhaps some possibility that in the future they may develop
something, and even if they do not, they are not a terribly
large group. They number in the hundreds, and one cannot
establish a probability effect of the order of say 10"4 or 5
or something of this kind in a study of the size of 100
people. So, I think we need to keep our perspective a
little clear.
I think the difficulty in the statement here that the
comparisons you are making with these high numbers was with
the proposed standard by the State Board of Health, and this
is essentially the background, and so the comparison really
was with the background level and not with the standard for
the MFC, so to say, from the plant.
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Dr. Johnson: I have just one final comment. I do want
to emphasize that the figures I gave were in relation to
background. The Colorado State Department figures are also
in relation to background, so the figures do sound rather
high, and I think they are of interest.
In response to Mr. Bean, I understand there was an
additional large area outside the area that has been paved
to cover the original spot where the barrels were located.
This area still has contamination equivalent to 2000 DPM per
minute per gram of topsoil, or 25,000 times the background
level. In addition, if you will look at the little table in
my written testimony, you will see that there are larger
areas with rather high levels of concentration, and all of
these are still subject to wind erosion.
In response to the sampling of the air, I have some
question about this procedure. In view of the fact that
there are strong gusty winds in this area, I wonder if the
actual monitoring instrument is going to reflect the actual
movement of this material along the soil? (Plutonium has
density similar to lead.) I am not an engineer, so I do not
know. That is all I have to say.
Chairman Mills: Dr. Morgan?
Dr. Morgan: Dr. Johnson, you indicated that there are
plans underway in Jefferson County for residential develop-
ment about in a one-mile square area, and that this was
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downwind from the Rocky Flats Plant. Question one, how far
is it from a facility in the Rocky Flats Plant, and two, as
the Health Officer in Charge in Jefferson County, have you
been working with the Rocky Flats people in the preparation
of an emergency plan, especially in view of this new
development?
Dr. Johnson: In response to your first question, if
you will turn to the last page of my written testimony,
there is a copy of a map of this area. On it you will see
an outline of the present land owned by the Rocky Flats
facility. The land in question to be developed borders
Indiana Avenue, which you will see approximately one mile
east of the eastern boundary of this plant. This plot would
extend from 96th Street to 108th Street.
Dr. Morgan: Have you been working with the Rocky Flats
people in the preparation of an emergency plan?
Dr. Johnson: In response to your second question, I
have not, and I think such a plan should be developed.
Chairman Mills: Thank you, Dr. Johnson. We will have
a ten-minute recess. We will reconvene in ten minutes.
(Whereupon, a short recess was taken.)
Chairman Mills: The next speaker for the day is Dr.
John Seiner from the Colorado Medical Society. Dr. Seiner?
Dr. Seiner: Gentlemen: I would first off like to
point out that I am going to make a statement for the Medical
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Society. This statement is on behalf of the Medical
Society. Any comments I might make aside from that,, I have
not been authorized to make by the Colorado Medical Society.
We understand the intent of these hearings is to inquire
into the need for establishing additional standards for
transuranium substance exposure. The Colorado Medical
Society appreciates the opportunity to address itself to
this subject.
Colorado, it would seem, is in a unique and dubious
position regarding exposure to these toxic materials.
Because of the irreversible nature of a miscalculation in
this area, the degree of competence demanded in decision
making when ionizing radiation is concerned is extreme. The
mining, processing, and distribution of waste materials with
these capabilities has resulted in important health threats
to Coloradoans. Some of these health threats have been
predictable and result from failure to demonstrate demanded
competence and responsibility on the part of the atomic
industry, the AEC and its congressional controllers, and the
Joint Committee on Atomic Energy. The experience with the
uranium miners, the use of uranium tailings for home and
public buildings in the Grand Junction area, the ongoing
contamination of Colorado surface in subterranean water
supplies, and the local plutonium contamination by the Rocky
Flats Plant names but a few such instances. The attempt to
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cover up the potential hazards that the 1969 fire at Rocky
Flats Plant held for the front range of Colorado should give
pause to all charged with the safety and well-being of the
citizens of this state.
The Colorado Medical Society in conjunction with the
State Health Department has studied these matters in great
detail. We conclude that there is a need for establishment
of a working principle regarding ionizing radiation. The
exposure of living things to unnatural radiation is harmful.
Given the validity of this premise, we believe that the
nine general principles summarized in the BEIR report of the
"National Academy of Science," 1972, serves as an appropriate
guideline from which to establish subsequent standards. We
endorse the concept of consideration of relative risk against
relative gain. Relative risk here has to be defined both in
potential for genetic and somatic damage to living organisms.
We feel that total body exposure consideration is appropriate
to certain types of ionizing radiation but that isolated
fixed exposure can become a primary consideration. We would
like to focus specific attention on Section G, Page 9, of
the BEIR report under Summary and Recommendations. Here
occupation exposure would apply to individuals living in
close proximity to facilities such as the Rocky Flats Plant.
Given the natural climate and atmosphere conditions peculiar
to the location of this facility, standards established for
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another locality might not apply here. The arid conditions
that promote the suspension of particulate matter as an
airborne dust together with the wind velocity experienced in
this locality create conditions for an increased probability
of the inhalation of radioactive materials from this facility.
Assuming there would be no risk of an accident similar
to the 1969 experience at Rocky Flats, which could have
resulted in a massive release of radioactive material, one
still must deal with the probability of inadvertent release
of toxic materials. Disclosures of release from stockpiled
waste materials was predictable. The more recent discovery
of contamination of municipal water supplies distant from
the plant and cattle on the grounds of the plant all support
the reality of this concern.
The recent discussions of acceptance of safe lung loads
for workers at the Rocky Flats Plant is a good case in
point. Plutonium materials can reach human beings by inges-
tion, i.e., water, plant, animal, or food where it can be
concentrated in the process of plant and animal metabolism.
Plutonium can be inhaled. In either case, it is either a
soluble substance that then can locate in regional lymph
nodes and bone marrow on a very permanent basis, or it is
inhaled as a particulate substance, again on a very perman-
ent basis. Cells proximal to the implantation area are
subjected to a constant radiation exposure. All evidence
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suggests that this affords optimal conditions for the
induction of a malignant change whether we are discussing
lymph, bone marrow, or lung cellular exposure. The Colorado
Medical Society does not view this as a speculative considera-
tion. Rather we consider this type of exposure an imminent
threat to health. We believe this position is supported by
the overwhelming weight of presented evidence.
Reassurance of Dow officials of the relative safety of
known lung exposures based on prospective data is not con-
vincing. Current methodology for assessing exposure on the
basis of total body counting and extrapolation to approxi-
mate lung burdens and systemic estimations based on urinary
excretion analysis could be at best described as educated
guessing. A persuasive parallel to this dilemma can be made
with the recent experience with asbestos. It is now known
that 20 to 25 years after the inhalation of asbestos dust
particles an alarming incidence of mesothelioma has been
described. This is a highly malignant tumor of the lung.
This is only realized, however, after many years of apparent
good health on the part of these workers. With the evidence
that has been accumulated establishing the risk of chronic
long-term exposure of cellular materials to radiations, as
would be the case with the inhalation of plutonium particles,
the Colorado Medical Society is forced to conclude that the
only safe level for a given individual is zero. We are very
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aware that this ideal is not achievable because of the
background plutonium contamination which is now worldwide as
a result of atmospheric explosions of atomic weapons. We
are also very cognizant of the predictable increase in
background levels as atmospheric contamination continues to
precipitate on the earth. Therefore, we recognize that the
risk of inhalation and general exposure to transuranium
substances will be with us regardless of establishments of
standards at this time. The average background concen-
trations for plutonium in the front range area is 0.08
disintegrations per minute of plutonium per gram of dry
soil. The 0.2 DMG standard recommended by the Colorado
Health Department in March of 1973 was considered ultra-
conservative. This figure was raised to 2 DMG after
considerable analysis. The Colorado Medical Society views
any attempt to further raise this standard at this time as
inconsistent with efforts to assure the safety of the people
of this area.
Considering relative risk versus relative benefit, the
Colorado Medical Society strongly urges the Congress of the
United States and the Environmental Protection Agency now
charged with overseeing environmental implications of
radiation exposure to consider the following:
1. The operation of the Rocky Flats Plant is directed
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almost solely at the development of component
parts for nuclear warheads.
2. The defense establishment of this government
presently possess in deliverable form capabili-
ties of destroying all human life on this planet
many times over.
3. Further development of this nuclear potential and
further sophistication of available delivery
systems is implicit in the continued operation of
the Rocky Flats facility and the recent agreement
between the United States and the Soviet Union.
Although we recognize the imperative need for a strong
defense position in this country, the medical community of
Colorado is not convinced that the continuing acceleration
of our nuclear defense posture is in the best interest of
the people of this country. We believe this capability
cannot be employed without assuring the very destruction of
the people it has been developed to protect. We do not
recognize the rationale of subjecting our citizenry to a
technical endeavor that in our judgment would only guarantee
an unacceptable risk.
That is the end of the statement.
Chairman Mills: Thank you, Dr. Seiner.
In your statement, and correct me if I am wrong, but I
understood you to say that you had determined that non-
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natural radioactivity is harmful?
Dr. Seiner: Yes.
Chairman Mills: Are you making a distinction between
natural radioactivity and non-natural radioactivity?
Dr. Seiner: Well, first I want to say that I am not
engaged in either study or research in nuclear medicine, and
I am not a nuclear physicist. I am a practicing medical
doctor. I am not a radiologist. I would like for you to
understand that.
Yes, I think you have to make that distinction, because
there is nothing you can do about the background that is
already there, yes.
Chairman Mills: Do you also see that there is a need
for any kind of distinction to be made between situations
that may require some corrective action as in the case of
contaminated soil as opposed to that for plant releases of
material, what might be effluent guidelines? Do you in your
own mind make a distinction between the needs? These two
needs are somewhat different.
Dr. Seiner: If the problem already exists, and it is
there, and you are talking about a possibility of additions,
yes, I think they are two different things.
Chairman Mills: Any other questions? Dr. First?
Dr. First: I am not sure I understand what the recom-
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mendations of the Colorado Medical Society are outside of
the area of global strategy, just what standards the Society
is advocating, assuming that we are going to continue to use
plutonium for at least military purposes and research for
some foreseeable period?
Dr. Seiner: I will leave a copy of the statement.
What we are recommending is that the level of 2 DMG which
was recommended by the Colorado Health Department be
supported, and we do support that recommendation.
Dr. First: On what basis? Do you have some infor-
mation which would translate this into human exposures and
projected or predicted human illnesses, or is this just in
response to the State's presentation of an earlier time this
morning?
Dr. Seiner: I think I am familiar with some of the
research which has led to that recommendation, and the
thought processes that has gone into that recommendation on
the part of the Health Department, and I would say, yes,
this is basically one of the most important of our thoughts.
However, I think it is also very important to recognize that
a good deal of data that some of these statements I heard
being made with the previous speaker are based on exposure
evidence on very small numbers of people for obvious reasons
You cannot go out and expose a large group of folks to
radioactivity in order to find out if it is harmful.
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Statistically it is extremely difficult to draw conclusions
on the basis of those limited sample populations. One thing
that is known, and I think there is good documentation for
this and references can be provided if you so desire, is
that there is an extreme variability in individuals and
their tolerance for various toxic things, and certainly
radioactivity is no exception to that. So, you need a very
large population of people in order to draw some conclusions
for safety that have been drawn.
Dr. First: Well, I think we all recognize that. I
must say that I am a little disappointed that the entire
medical fraternity of the State of Colorado makes a state-
ment with no medical toxical information contained in it. I
had hoped that this would be a good medical review of the
problems of bringing out points which would be particularly
pertinent to medical concerns.
Dr. Seiner: I think it was the judgment of the Society
that that information is being brought out by such as the
Department of Health for the State.
Dr. Garner: I would like to point out that although
you may like to try to distinguish between natural and what
you call perhaps unnatural radioactivity, the body cannot
distinguish between the two, and the effects of any
naturally-occurring activity are indistinguishable from
those of the effects of any man-made activity. You said
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that we could not reduce the intake by inhalation to zero
because of background plutonium. In fact, we could not if
there were no background plutonium because regrettably, and
perhaps to some in this area there is an awful lot of
uranium in the rocks, and so dust, anything you breathe,
will contain naturally-carrying uranium, which also and its
daughters emit alpha activity just like plutonium. So that,
come what may, if we breathe dust in this area, we are
exposed to alpha activity.
Dr. Taylor gave a figure, he said about 10 curies per
square mile in daughter products. Now, my arithmetic may
well be in fault, because I have just scribbled that out,
but that works out to me to about 4 microcuries per square
meter, and the Colorado Health Department standard, you will
recollect, is 2 DPM plutonium, which is the equivalent of
about .01 microcuries per meter square. This figure has
been lowered by a factor of four-hundred from what occurs
naturally. I am just trying to get this thing into perspective
We are here worrying about man-made activity, which is in
fact a small fraction of what is there unavoidably. The
body cannot distinguish.
Dr. Synder: I too would like to comment on your use of
the threat to health. As I understand it, the State standard
was not based on any demonstrated or even suspected threat
to health. It was based on the levels found in the environ-
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ment, and consequently there was no threat to health except
by extrapolation from higher numbers, and as has been pointed
out, this extrapolation would lead one to find higher threats
to health from the natural emitting alpha nuclides.
Dr. Seiner: Doctor, the reference to threat to health
was not in reference to this standard. The reference to
threat to health was in reference to other occurrences in
this state where I think the threat to health has been very
clearly established. If you recall, it was in reference to
the experience with uranium miners and the situation in
Grand Junction with regard to radon gas and its daughters.
That is what the reference was about.
Chairman Mills: Thank you very much, Dr. Seiner.
The next speaker is Dr. John Cobb of the University of
Colorado Medical Center.
Dr. Cobb: I believe you have copies of my paper?
Chairman Mills: Yes, we have.
Dr. Cobb: My name is John C. Cobb. I am Professor of
Preventive Medicine at the University of Colorado Medical
School.
As a member of the Rocky Flats Task Force appointed by
Governor-elect Lamm and Congressman-elect Wirth, I have
spent much of the Christmas and New Year holidays reading
reports, documents, books and papers related to plutonium
pollution as a possible danger to the health of citizens of
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Colorado. I do not recommend this for a Christmas vacation.
Never, in a rather varied career of more than 30 years in
medical and public health, have I come upon a field with so
much controversy and so little well-substantiated infor-
mation. Part of the trouble, of course, stems from the
secrecy which necessarily surrounds the atomic weapons
program; but much of the trouble evidently has come from the
public's growing concern that citizens are being exposed to
an unknown, invisible, odorless, silent peril as a result of
mistakes, carelessness and accidents in the handling of
plutonium. People suspect that the facts about these occur-
rences have been unnecessarily kept secret in order to
protect those who were responsible. Repeated denials and
attempts to cover up, followed by later admissions by the
AEC and its contracting agencies, and given vigorous
coverage by the news media, have gradually built up an aura
of suspicion and mistrust of the AEC. The whole "Watergate
Affair" has evidently not improved the public's feeling of
trust in our Government.
Another reason for the mistrust is the unfortunate
inadequacy of checks and balances on the AEC. The very same
agency that was involved with promoting the expansion of all
kinds of uses of atomic energy was also responsible for
establishing controls under conditions where secrecy could
be used to prevent scrutiny by outside experts and to
prevent public discussion of issues such as health and
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safety of citizens.
Value decisions of life and death importance to
citizens of today and to future generations of all living
things were made virtually without public discussion. The
public had no opportunity to weigh the risks of plutonium
pollution against the benefits of atomic weapons or atomic
power plants. We were simply left in the quiet dark with
our fears. Each whisper of information leaking to scared
people was amplified in the reverberating circuit of public
alarm. Now in this atmosphere of alarm and mistrust, it is
most difficult for a reasonable value decision to be made.
Nevertheless, it must be done. The recent reorganization of
the AEG, the court case leading to the legal involvement of
the EPA, the creation of the Rocky Flats Task Force are
welcome developments. Citizens can now look forward to less
secrecy and more opportunity to be involved in decision
making. Scientists like myself have the duty to present as
clearly as possible what the known facts are, what the
uncertainties are, and what research is necessary to get the
answers we need. The public then, through its representative
government, must decide what to do. No scientist or AEC
administrator should be allowed to make such decisions
involving human values like sickness and health, like the
protection of our way of life from foreign powers, or possible
destruction of a large part of the living things in the
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world, without input from ordinary citizens who have had an
opportunity to be thoroughly informed on all sides of the
question.
It is my intention, therefore, at this public hearing,
to do my best to summarize some of the evidence and un-
certainties regarding the difficult job of setting safety
standards for minute particles of the oxide of plutonium-239
such as are being blown from Rocky Flats into the air breathed
by the citizens of Colorado.
Let us review some of the data. The most liberal point
of view regarding safety standards that I have encountered
comes from data on a 27-year study of 25 selected Los Alamos
plutonium workers. These men got relatively heavy doses
plutonium in various forms. (Unfortunately the details of
the amount or the form in which the plutonoum was inhaled
was known only very roughly because of the lack of sophisti-
cated monitoring equipment which was available at that time,
1944 to 1945.) The estimated body burdens of plutonium
ranged from 0.1 to 1.2 micrograms of plutonium, that is
6,000 to 80,000 picocuries, a very large dose by today's
standards. The authors of this study, Hempelmann, Richmond
and Voelz, in their informal report state that "to date,
none of the medical findings in the group can be attributed
definitely to internally deposited plutonium ...we conclude,"
I am still quoting, "that the body has protective mechanisms
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which are effective in discriminating against these materials
following some types of occupational exposures."
Certainly the fact that these 25 men with such a body
burden have survived 27 years without serious effects proves
that such plutonium exposure is not uniformly harmful nor
even necessarily carcinogenic. This is reassuring to those
who have been exposed. Does this mean that doses of this
level or less are harmless? Certainly not. It would be
somewhat comparable to say that because 25 men returned
safely from an expedition to climb Mt. Everest, that climb-
ing mountains was therefore safe and that exposure to high
altitude and cold is harmless.
A more pertinent question would be: What is the smallest
exposure to plutonium which has been clearly shown to cause
harm? Perhaps the smallest reported harmful human exposure
was that of a machinist who received 0.08 micrograms, that
is 30 millionths of an ounce, of plutonium-239 from a puncture
wound in his hand. Lushbaugh and Langham (1962) reported
that after four years it produced a nodule which displayed
precancerous changes. Numerous animal experiments suggest
that even smaller amounts of plutonium-239 inhaled as very
small particles, that is, 0.1 - 0.5 microns diameter, into
the deepest recesses of the lung may cause lung cancers.
These data may or may not be applicable to man.
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Now the most pertinent question is the following: How
small a dose of plutonium is likely to be harmful to enough
people, so that the risk to society, I am talking about an
exposure to a large number of people, so that the risk to
society would not be worth the possible benefit? Here we
get into the difficult area of estimating probabilities and
the more difficult area of value judgments. Unfortunately,
we cannot get a very good estimate of the probable risk
involved in very low plutonium exposures because the people
who have had such low exposures, like the people who live
downwind from Rocky Flats, have not been adequately followed
and studied. I might add that even the people who have
worked at Rocky Flats have not been adequately studied.
That is, the whole population has not been studied. Those
who have left employment there cannot be followed because
there is no legal way of forcing them to be followed.
Futhermore, for those few employees of Rocky Flats with
known exposures who have been followed and studied, the time
interval is too short. It evidently takes about 30 years
for cancers of the lung to develop as a result of this kind
of radiation.
Much more serious for the long-term future of mankind,
is the possibility that plutonium-239, with a half-life of
over 24,000 years, may find its way from the lung into the
gonads where it may affect the germ cells and cause con-
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genital defects in future generations. In fact, appreciable
concentrations of plutonium have been reported by Campbell
and others in the gonads of deceased men who came to autopsy
via the medical examiner's office, this was due to accidents,
crime, etc., in New York City. They were not considered to
have been occupationally exposed to plutonium, but their
occupations were not reported in the data available to me.
Measurements of the amount of plutonium-239 found in the
testicular tissue of 26 subjects from New York City revealed
that three of them showed more than 7 disintegrations per
minute per kilograms of tissue and one of them showed 19.0
dpm/kg, whereas the highest measurement on the lungs of the
same subjects was only 2.27 dpm/kg. These data suggest that
plutonium inhaled from the air passes through the lungs to
the gonads in appreciable concentration. There it may
damage the chromosomes of sperm cells which could lead to
serious congenital defects of the offspring and of future
generations. Further research on this is greatly needed.
And, in addition, we need to review, as I mentioned before,
the history of the people who have been exposed, not just
the ones who are still working, but the ones who were work-
ing in the past at Rocky Flats and other places and those
who live nearby. We need to review the data that is avail-
able from the Rocky Flats sponsored study of chromosome
breaks in people who are now working at Rocky Flats, and we
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need to probably start many more studies. But, we do need
to find out as much as possible about this danger.
A number of researchers are now looking at various
possibilities that very small amounts of plutonium-239,
perhaps 1-thousand times less than present standards,
inhaled in the form of plutonium oxide, may cause cancer in
the lungs. Dr. Martell will report on his hypothesis and
related findings later today. I have been asked to review
briefly the "hot particle" hypothesis of Tamplin and Cochran
(1974).
I would like to emphasize that this "hot particle"
hypothesis has not been proven nor is it generally accepted.
At the same time, data are lacking to disprove it. I asked
Professor William Hendee to review Tamplin and Cochran's
paper critically. He is head of the Division of Therapeutic
Radiology at the University of Colorado Medical School and
is more conversant than I with these matters. I would like
to include his comments in the written testimony which I am
submitting today, with his permission; and it is attached to
the document that you have. Briefly he concludes that there
are so many uncertainties in the basic data on which the
hypothesis is supported in this paper, that the "hot particle"
controversy remains unfortunately still unresolved. Further-
more, there are theoretical reasons for questioning this
hypothesis, as Dr. Martell pointed out to me. These same
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theoretical considerations regarding the "hot particle"
hypothesis do, however, lead him, that is Dr. Martell, to
recommend an approximately equally stringent set of stand-
ards for small insoluble plutonium particles in air.
Now let me briefly summarize this hot particle hypo-
thesis: Briefly this hypotehsis is that a very small insol-
uble particle of plutonium 239 of about 0.1 to 0.5 microns
in diameter containing at least 0.07 picocuries, if it were
inhaled and lodged in the deepest recesses of the lungs,
would remain there for some years and continue to radiate
the surrounding cells with alpha rays. Because the range of
these alpha rays in lung tissue is very short (about 45
microns), just a few cells, this would result in a rela-
tively large dose of radiation (at least 1000 rem/yr) to a
small number of cells. Assuming that the likelihood of
cancer production is dependent on the intensity of radiation
of those few cells, Tamplin and Cochran reason that such
small "hot particles" of plutonium are more likely to cause
cancer than if the same amount of radiation were evenly
dispersed in the lung tissue. On this basis they argue that
for nonoccupational exposure, the maximum permissible lung
particle burden of plutonium-239 should be set at 0.2 hot
particles, on the average, per person; with the correspond-
ing maximum permissible concentration in the air being 9x10"18
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micro curies per cm3, and the corresponding maximum permiss-
ible surface concentration for unrestricted areas being 1
hot particle per square meter. For comparison, monthly
composite measurements of the ambient air in Denver run
about twice this suggested limit according to the 1973
Annual Environmental Monitoring Report of Dow Chemical, and
the concentration in the soil just to the east of Indiana
Avenue near the east entrace to the Rocky Flats plant outside
the perimeter of the property runs about 0.1 microcuries per
square meter which would be more than one million hot particles
per square meter, assuming that all of the plutonium were in
particles of the size referred to above, that is containing
0.07 picocuries each. It is, of course, more likely that
the large particles have settled out near the Rocky Flats
Plant, while the smallest and most dangerous according to
the hypothesis, the most dangerous ones have blown into
Denver for us to breathe.
Now, as to a basis for setting standards. Obviously
the Tamplin and Cochran hypothesis does not present a suit-
able basis at the present time. It is based on data which
as I have said is not reliable enough, and it has not been
generally accepted. Yet, it has not been disproved, and I
feel that we have to remember this and work to get the data
that we need to settle these questions.
As one who is primarily concerned with the health of
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the public, now and for future generations, I feel it would
be desirable to assume the worst, set temporary standards
accordingly now, and get on with the needed research. Let
me re-emphasize that I am particularly concerned about the
possible effect of plutonium on sperm and egg cells in the
gonads and its consequent possible harmful effects on future
generations. If we should make a mistake now, and inadver-
tently allow plutonium to seriously contaminate our environ-
ment to a level of say 1000 times too high, which some
researchers believe to be the case, including Tamplin and
Cochran, we would have to wait for a quarter of a million
years before it would decay back down to the acceptable
level. By that time the human race might long be gone from
this earth. We are gambling with the future of life on this
earth; the probability of losing may be very, very low, but
the stakes are very high; I urge a conservative and cautious
approach to the setting of plutonium standards.
Now, we have heard about risk versus benefit analysis.
I would like to add another aspect to what has already been
said. I would like to return now to my opening remarks
about risk versus benefit analysis. I think it will help to
clarify the issues and to make decisions if we try to answer
these questions.
First of all, who and how many are the ones who would
benefit from continued plutonium production allowing con-
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tinued pollution at present levels?
And the second question, who and how many are the ones
who would benefit from setting conservatively safe standards
now for plutonium in the environment with the possibility
that we might change them later to a higher level.
First to take those who would stand to benefit from
plutonium production, they are not only the 2,900 people who
work at Rocky Flats, not only the stockholders of Dow
Chemical and Rockwell International, but all of the people
of the United States of America who, according to George
Wald, (1974) are spending twenty million dollars a day on
nuclear arms for the "MAD" program, twenty million dollars a
day. This "MAD" stands for Mutual Assured Destruction.
That is not a joke. We are making about three new hydrogen
bombs every day, and the USSR is keeping pace with us. The
purpose, on both sides, is to preserve a way of life --
Democracy or Communism or something -- which from our present
perspective we think is more important than life itself.
Using these hydrogen bombs would assure our mutual destruc-
tion. MADness indeed!
Now to look at the other side of the ledger, setting
conservatively safe standards might mean that we would have
to stop making nuclear weapons. If the whole world could
agree, none would be the losers except those who are now
making a living or a profit from the nuclear weapons
-------
industry. Who and how many are the ones who would stand to
benefit?
Those who would stand to benefit from such rigorous
standards that might require stopping nuclear production
would be not just all the people who are breathing air
contaminated with plutonium, not just the people living,
laughing and loving in the United States or Russia or any
other place, any other "hostile" country who would be spared
mutual assured destruction, not just the total population of
the world today who would be spared from the killing and
crippling radioactive fallout; those who would stand to
benefit are all the people and animals and plants of future
generations -- the descendents of ourselves and every living
thing which might live in the world in the next million
years. These are the ones who would benefit most from
setting a plutonium standard safely and conservatively, and
of course from preventing nuclear war.
Some say that increasing the radiation exposure that
everyone gets would speed up evolution and would be a good
thing. By causing congenital anomalies, it might even
reduce the birth rate and thereby control the overpopulation
of humans, which some think would also be a good thing. But
fortunately, and this is in my particular field, there are
better and surer and far safer ways to accomplish both these
things -- if we should decide they really would be good.
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248
The change that any mutation or chromosome break caused
by ionizing radiation might be beneficial, thereby advancing
our evolution, is approximately the same as the chance that
a clock would keep better time if you were to shoot at it
with an elephant gun. You would have to shoot holes in
millions or billions of clocks, spoiling almost all of them
in the process, in order to get one that actually kept
better time as a result. This is not the way I would choose
to do it.
I urge the EPA, in setting standards for plutonium in
the environment, to be cautious and conservative and respect-
ful of all living things, now and for forty thousand genera-
tions of human life to come. A million years from now, they
will thank you.
Thank you.
(Applause.)
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249
REFERENCES
Campbell, E. E, Milligan, M. F., Moss, W. D., Schulte, H. F., and
Mclnroy, J. F. (1973), "Plutonium in Autopsy Tissue", Report LA-4875, UC-48,
January 1973 of the Los Alamos Scientific Laboratory, US AEG.
Dow Chemical 1973 Annual Environmental Monitoring Report, REP-ENV-73
issued April 27, 1974.
Hempelmann, L. H., Richmond, C. R., and Voelz, G. L. (1973), "A Twenty-
Seven Year Study of Selected Los Alamos Plutonium Workers", Informal Report
LA-5148-MS of the Los Alamos Scientific Laboratory, US AEC. (Available
from National Technical Information Service U. S. Department of Commerce,
5285 Port Royal Road, Springfield, Virginia 22151)
Lushbaugh, C. C. and Langham, J. (1962), "A Dermal Lesion from Implanted
Plutonium", Archives of Dermatology 86, pp. 121-124.
Tamplin, A. R. and Cochran, T. B. (1974), "Radiation Standards for Hot
Particles" a Report to the EPA and AEC, available from the Natural Resources
Defense Council, 1710 N Street, N. W., Washington, D. C. 20036.
Wald, G., Editorial, Bull. Atom Scientists, Dec. 1974.
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250
Form 365
TO
FROM
UNIVERSITY OF COLORADO MEDICAL CENTER
Inter-off ice Communication
Jock Cobb
DATE
Bill Mendee
SUBJECT: Comments on the Paper "Radiation Standards for Hot Particles"
by Arthur R. Tamplin and Thomas B. Cochran
With but one exception, radiation protection standards for internally
deposited radioactive materials are based upon the assumption that
the materials are distributed in such a manner that the radiation
dose to the critical organ is relatively uniform. The one exception
to this practice is the standard for 226Ra, where the maximum permissible
skeletal burden of 0.1 yg is based upon extensive studies over many
years of the relationship between the skeletal burden of 226Ra and
the incidence of osteogenic sarcoma. A second radionuclide for which
the uniform dose model may not be appropriate is 239Pu in insoluble
form as small particles (<0.6 y) whidh may be inhaled and deposited
in the deep respiratory tract for long periods of time. Unfortunately,
the types of human experience which gave rise to the 0.1 yg skeletal
limit for 226Ra are not available for 239Pu.
Because of the absence of experimental data concerning the biological
risks associated with deposition of insoluble 239Pu particles in the
lung, controversy has surrounded the application of radiation
protection guidelines based upon uniform dose assumptions to this
health physics problem. This controversy has existed for a consider-
able period of time, and is now identified as the "uniform dose vs.
hot particle" controversy. This controversy is the focal point of
Tamplin's and Cochran's paper.
In their paper, Tamplin and Cochran call for some remarkable changes
in present radiation protection standards in terms of their applicability
to hot particles, particularly 239PuO,,. For example, the authors
propose that the maximum permissible lung burdens and maximum
permissible concentrations in air for occupational and non-occupational
exposure all be reduced by a factor of 115,000 fW 239Pu in the form
of insoluble hot particles. Furthermore, Tamplin arid Cochran suggest
that the exclusion areas for nuclear reactor sites, nuclear fuel
processing plants, and nuclear energy research establishments should
be expanded so that no individual at the exclusion site boundary for
2 hours immediately after accidental release of radioactive material
would receive a lung particle burden in excess of 10 hot particles.
I am unsure of all of the implications of these recommendations with
respect to the development of nuclear power facilities and maintenance
of a nuclear weapons program, but suspect that the proposed recommenda-
tions would seriously handicap, if not cripple, both Industries.
Whether either industry could continue to function, and at what cost
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251
-2-
to the taxpayer in terms of the improvements required in safety
procedures, should be investigated thoroughly before any actions are
taken on the proposed standards. The final decision will undoubtedly
be a matter of judgment rather than objective appraisal of data,
because good data related to this problem simply are not available.
Nowhere is the lack of good data more apparent than in the paper by
Tamplin and Cochran. For example, the paper by Albert £t_ a_1_. is
quoted extensively (Figures 1 and 2), but the decrease in tumor
incidence with dose above 2000 rads is not mentioned, although this
feature certainly has some importance with respect to extension of
Albert's data to the 239Pu02 problem, particularly in relation to
the dose to tissue near a plutonium particle. Also, no particular
attention is directed to the influence of dose rate on tumor induction,
except to say that the tissue repair time is probably 1 year for the
lung, an assumption based upon a model for the lung which is founded
on very little biologic data. These and other difficulties cause
me to question the 1000 rems/year threshold dose rate postulated in
the paper as the criterion for defining a hot particle. Because of
these difficulties, the explanation by the authors as to why none of
the 25 Manhatten Project workers has developed lung cancer (i.e., the
dose rates are lower than 1000 rem/year) seems to rest upon a rather
arbitrary criterion. Animal data quoted by Tamplin and Cochran as
most relevant to any consideration of radiation standards for hot
particles are those collected by Bair and his colleagues on studies
of 239Pu02 inhalation in beagles. The authors conclude from these
data that induction of lung cancer is a certainty during the life
span of the participating animals. Interestinqly, Bair is also one
of the three authors of a report entitled WASH-1320: A Radiobiological
Assessment of the Spatial Distribution of Radiation Dose from Inhaled
Plutonium (November 197**). Conclusions in this report include:
1. Recognizing the importance of spatial distribution, researchers
have continued to study its fadiobiological aspects, but
"continued examination...especially as regards alpha-emitting
particles, has not led t6 major changes" in standards.
2. "...truly uniform distributions of inhaled radionuclides in
lung seldom, if ever, occur. However, because of the
mobility of plutonium within lung, there iS some biological
justification for averaging the radiation dose to the total
tissue."
3. Comparisons of uniform and nonuniform distributions "suggest
a biological sparing effect for both acute and late responses
to the non-uniform distribution. Available experimental data
indicate that averaging the absorbed alpha radiation dose
from plutonium particles in lung is radiobiologica1ly sound."
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252
-3-
*». "Consideration of mechanisms of radiation carciinogenesis
suggests that there has been no change in direction 6r
strength of data which would compel departure from the
concept that average lung dose for alpha particles provides
a reasonable and conservative base for protection."
5- Over thirty years of experience with plutonium indicates
"there is no evidence that the mean dose lung model on which
occupational radiation protection standard^ for plutonium are
based is grossly in error or leads to hazardous practices."
Since data from exposed persons indicates non-homogeneous
distribution does not result in greater risk than uniform
distribution," empirical considerations lead to the conclusion
that the non-uniform dose distribution is not more hazardous,
and may be less hazardous, than if the plutonium were uniformly
distributed...."
I believe that in essentially all of the anima? and human data which
Tamplin and Cochran quote in support of their proposal to reduce
radiation protection standards for plutonium particles, one can find
similar uncertainties regarding the data on the ways in which the
data are used in defense of the proposed standards change. Similarly,
I believe that risk estimates based upon multiplication of a small
estimated risk times a large population have an equally uncertain
significance. Hence, I am unable to get very excited about Tamplin
and Cochran's paper. This unwillingness does not reflect a blase
attitude on my part about the uniform distribution versus hot particle
dose controversy. It means simply that I do not believe Tamplin and
Cochran have contributed anything very meaningful towards its resolution.
cc: Theodore T. Puck, Ph.D.
Arthur Robinson, M.D.
Marvin L. Daves, M.D.
-------
EDITORIAL
Arise
n
JL
53
(Reprinted by permission of the Bulletin
of the Atomic Scientists and the author.)
GEORGE WALD
I have come halfway across the world to speak
what 1 believe to bo the truth. It is a dreadful truth,
hard to live with. But if we do not live with it, we
shall die by it.
1 speak here as an American, but even more as a
fellow human being, a scientist concerned with life,
a teacher deeply troubled for my students, a parent
fearing for my children and for their children.
Human life is now threatened as never before,
not by one but by many perils, eacli in itself cap-
able of destroying us, but all interrelated, and all
coming upon us together. I am one of those scien-
tists who does not see how to bring the human race
much past the year 2000. And if we perish —as
seems more and more possible —in a nuclear holo-
caust, that will be the end not only for us but for
much of the rest of life on the Earth.
We live —while that is permitted us —in a bal-
ance of terror. The United States ar.d the Soviet
Union together have already stockpiled nuclear
weapons with the explosive force of 10 tons of TNT
for every man, woman and child on the Earth. You
might think that enough, but both countries are
now in the midst of further escalation, replacing
every single nuclear warhead with multiple war-
heads and devising new and more devastating
weapons.
My country at present is making three new hy-
drogen warheads per day. The Soviet Union keeps
pace with us. We are told that our security (strange
thought) lies in Mutual Assured Destruction —
MAD. It is well-named.
The bomb that destroyed Hiroshima, and ended
by killing about 100,000 persons, was a small one
by present standards, with the explosive power of
about 15,000 tons of TNT.
One of my friends about 10 years ago was able to
look up what we then had targeted upon a Russian
City about the size of Hiroshima. It was in the mega-
ton range, several hundred times as large. Why?'
One can only destroy a city. One can only kill a
person. It is insane —but the insanity of the prac-
tical and calculating persons who run our lives. It
is insane —unless one holds an arms contract. Then
it is business, and the bigger the better.
The United States now budgets about $22 billion
a year on new arms. A rapid rate of turnover as-
sures that this business will go on. Our arms sales
abroad doubled in 1973-74 over the year before —
$8.5 billion, about $7 billion going to the Middle
East. When early in 1971 the Joint Economic
George Wald delivered this speech last August in
Tokyo at the 20th World Conference Against Atomic
and Hydrogen Bombs. He is Higgins .Professor of
Biology at Harvard University, and a 1967 Nobel
laureate in physiology or medicine.
(Copyright (c) 1974 by the Educational
Foundation for Nuclear Science.)
(JommiUcc 01 Congress asked a general trom our
Department of Defense how much military hard-
Ware the department then held that had been de-
clared surplus, mainly to be sold as scrap, he re-
plied $17 billion Worth.
The nuclear arms contracts alone are worth
about $7 billion a year. Seven billion dollars talks
more loudly than any number of humanitarian dec-
larations or terrified people or children facing ex-
tinction. That money is real, hard cash. Where it
changes hands, those consequences are out of sight,
hence out of mind —mere abstractions.
The Jiiff Hunger
But arms, arid war, and nuclear weapons are
only part of the crisis. The big hunger is now upon
us, the great famines that scientists have been
predicting for years past: hunger among the poor in
the developed countries, starvation in Africa, South
Asia and South America.
The Green Revolution, so recently begun, has
already collapsed. It depended on huge supplies of
cheap oil and coal to prepare the artificial fertiliz-
ers and pesticides that alone rhade it work. And oil
and coal are no longer cheap. The profits of the
major oil companies —which also own most of the'
coal and are now developing nuclear power—dou-
bled and tripled during the past year ns the peoples
of the Third World began to starve. It seems possi-
ble that '20 million persons will die of famine dur-
ing the next 1'2 months in India, Pakistan and
Bangladesh alone.
All those problems are made more terrible by the
population explosion. We have not yet quite taken
in what that means. Even if all the developed na-
tions reached the replacement level-an average of
two children per producihg pair —by the year 2000
and if all the nations of the Third World came to
the same state by 2050 (both conditions highly un-
likely), then the world population, which is now at
about 3.7 billion, would rise by 2120 to about 13
billion.
Development, so-called, has meant mechaniza-
tion. The work that used to be done by human and
animal muscle is increasingly done by machines.
That is true even in agriculture. It is another as-
pect of the Green Revolution. Farming is rapidly
being replaced by 'agribusiness.'
In the United States the sarhe huge corporations
that make aircraft, control our oil and gas and run
our transportation, also grow our food. Such agri-
business now controls 51 percent of our vegetable
production, 85 percent of our citrus crops, 97 per-
cent of our chicken-raising, and 100 percent of our
sugarcane. That is happening all over the world. It
means more food, but many fewer jobs. And only
those who find work can eat and feed their families.
Unemployment, that child of the Industrial Revolu-
tion, is rising throughout the world.
December 1974 Bulletin of (Ac Atomic Scientists
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254
And a new phenomenon has developed that is
much worse. With increasing mechanization, in-
creasing numbers of persons have become not only
unemployed but superfluous. There is no use for
• them in the free-market economy. They are wanted
neither as workers nor customers. They are not
wnntcd at all. Their existence is a burden, an em-
barrassment. It would be a relief if they vanished —
parents and children.
In his report to the International Bank for Recon-
struction and Development (World Bank) in Sep-
tember 1970, its president, Robert McNamara, for-
mer Ford executive and U.S. Secretary of Defense,
spoke of such persons as "marginal men." He esti-
mated that in 1970 there were 500 million of
them —twice the population of the United States —
and that by 1980 there would be one billion, and by
1990, two billion. That would be half the world
population.
It is too late for declarations, for popular appeals,
here or anywhere. All that matters now is political
power.
We call here for the abolition of nuclear weapons.
Even in the remote chance that Unit would happen,
it would not protect us from nuclear war. Those
nations that have already learned how to make
nuclear weapons would produce them in quantity
withm a few months of the outbreak of a new war.
Getting rid of the nuclear stockpiles would defuse
the present threat of instant annihilation; it would
gain us a little time. That would be an important
gain, but only a stop toward what must be the ulti-
mate aim: to abolish war. War is obsolete in the
modern world. It has become intolerably dangerous.
The only thing that can save us now is political
power—for the peoples of this world to take that
power away from their present masters, who are
leading our world to destruction.
Who are our masters? In the so-called Tree world'
it is not the governments. They arc only the ser-
vants, the agents. Nor is it the generals; they too
are only servants.
The free world is run by such enterprises as Gen-
eral Motors, ITT, the Chase Manhattan Bank,
Exxon, Dutch Shell and British Petroleum, Mitsu-
bishi and Mitsui. Their wealth and power exceed
. any previously known throughout human history.
We think of General Motors as a private busi-
ness; but only 18 nations in the world have gross
national products as large as the annual sales of
General Motors, $36 billion in 1973.
Those giant corporations can buy and sell, can
make and break governments. They stop at noth-
ing. A year ago Chile was taken over by a military
junta, its President Allende murdered, its great
folk singer Victor Jara beaten to death. But now
ITT, which offered our CIA $1 million to keep Al-
lende from becoming President, can operate freely.
And Anaconda Copper has just settled its claims
with the new Chilean dictatorship for $253 million.
And what of the 'socialist' world? It offers us an
imperialism of the left to balance that of the right.
We have had hard lessons tb learn during the past
years. One of thorn is that private wealth and per-
sonal political power arc interchangeable, bureauc-
racies arc interchangeable, generals and admirals,
corporate executives and industrial commissars-all
interchangeable.
Hence no nation so closely resembles the United
States of America as the Soviet Union. That is
what Andrei Sakharov told us a few,years ago; he
proposed that both nations now join forces to work
for the good of humanity. For that he is virtually a
prisoner in his own country. Policy in the modem
world, right or left, is not made by the Sakharoys.
We are often told indeed that even the experts do
not know how to deal with the problems that now
threaten worldwide disaster, that "all the facts are
not yet in," that more research must be done, and
more reports written.
By all means let us have more research. But that
must not be allowed to become a trap, an excuse for
endlessly putting off action- We already know
enough to begin to deal with all 6ur major prob-
lems! nuclear war, overpopulation, pollution,
hunger, and despoliation of the planet Earth.
The present crisis is a crisis not of information but
'of policy. We could begin to cope with all the prob-
lems that now threaten our lives. But we cannot
cope with any of them while maximizing profits. •
And a society that insists before all on maximizing
profits for the few thereby threatens disaster for
all. But not for all at the same time.
As matters now stand, the peoples of the Third
World are to perish first. They have already begun
to starve. All that is asked of them is to starve qui-
etly. If they make trouble, they will be extermi-
nated by other means.
The developed nations are armed to the teeth,
and they mean not only to hold on to what they
have but to grasp whatever more they can, while
they can —for example, the last of the world's
. rapidly dwindling natural resources. Another ex-
ample. As the great famines begin, the grain that
might feed a hungry peasantry throughout the
Third World is fed instead to cattle and hogs to
• supply the rapidly increasing demand for beef and
pork in the affluent countries. But the developed
• nations' turn will come too —first, of course, to
their poor, already hard-hit by worldwide inflation
and unemployment. And if there should be another
major war, as seems likely, a nuclear holocaust
would swallow up everything.
Unless the people of this world can come together
to take control of their lives, to wrest political
power from those of its present masters who are
pushing it toward destruction, then we are lost—
we, our children and their children.
Arise, ye prisoners of extinction. Peoples of the
'world, unite. You have nothing to lose but your ter-
ror, your exploitation and ceaseless deception, your
alienation and dehumanization, your helplessness
and hopelessness.
And a world to win. D
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255
Chairman Mills: Could I ask, are you aware of the
Transuranic Registry for Plutonium?
Dr. Cobb: I am aware of it, yes.
Chairman Mills: Does that meet some of the require-
ments you think for the study of population?
Dr. Cobb: It certainly meets some of the requirements,
but I would say not all.
Chairman Mills: With regard to the question of induc-
tion of lung cancer from transuranics, in your statement it
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256
evidently takes about 30 years for cancers of the lung to
develop as the result of this kind of radiation. What is
the basis for the 30 years as a latent period?
Dr. Cobb: This I got -- first let me say I am not an
expert in this field, and I have been reading up on it
during the past month, and I think I got it from talking
with Dr. Martell, who will be addressing you later today.
Chairman Mills: I will address Dr. Martell.
Another question, you are aware that Dr. Tamplin and
Dr. Cochran did present testimony?
Dr. Cobb: Yes, I understood you have the document.
Chairman Mills: On Page 5 of your testimony you speak
to the fact, "Measurements of the amount of plutonium-239
found in the testicular tissue of 26 subjects from New York
City revealed that three of them showed more than 7 dis-
integrations," and so on. I take it that you are drawing
here the inference that all the plutonium that deposited
itself in the gonads arose from air inhalation? No other
pathway was considered, that is, any kind of ingestion?
Dr. Cobb: The occupational history of the individuals
in this study was not in the data that I saw, so how could I
tell? But, I assume if they were not working with plutonium,
that they must have breathed it from the ambient air.
Chairman Mills: Any other questions?
Dr. First: I would like to ask one.
-------
Chairman Mills: Dr. First has a question.
Dr. First: Doctor, on Page 6 of your testimony, you
make a statement, that there are "...more than a million hot
particles per square meter" based on the measurements of
radioactivity in the soil, and you make the statement further,
and you relate this in your testimony to Tamplin and Cochran's
standard of a fifth of a particle per human. We are talking
about a million particles in a square meter of soil, and you
are referring this to a fifth of a particle in the lung.
Now, how do you make this connection?
Dr. Cobb: The standards that Tamplin and Cochran
recommended were two. One for the soil and another for the
lung, and I simply took their figures and related them to
the measurements made near Rocky Flats. Now, the standard
for the soil, as I said, was one hot particle per square
meter. The dose out there, the amount of plutonium in the
soil out there now would be about a million hot particles if
they were all of that very small size, which we do not know.
In fact, I suspect they are all large particles.
Dr. First: Well, Doctor, just for the sake of getting
on with this, let us assume there are a million particles
out there.
Dr. Cobb: Right.
Dr. First: Let us assume that Tamplin and his associ-
ates have stated that one fifth of a particle for a lifetime
-------
dose. Now, ray question to you specifically, how do you
relate one million particles in a square meter of soil to a
fifth of a particle in somebody's lung?
Dr. Cobb: Really what you are asking me is, "how do
Tamplin and Cochran do this?"
Dr. First: No, I do not think so, because I do not
ever remember them saying anything about a million particles
in a square meter of soil. But, I may have missed it.
Dr. Cobb: In their report, they did recommend one
particle per square meter of soil as a standard, and they
discussed the resuspension factor which we discussed this
morning. They pointed out that there is a variation of what
people consider to be right for resuspension factor of many
orders of magnitude. I think the variation is something
like maybe as many as 10 orders of magnitude in different
opinions.
Dr. First: I am suggesting that the connection between
these two has not been made by you or by Tamplin?
Dr. Cobb: Exactly why we need research. We need to
know what size the particles are outside of the Rocky Flats
Plant, and we need to know how many of them get resuspended,
not an average over 24 hours, but the peak concentraction.
We need to have many more monitoring stations along Indiana
Street and around the plant, because as the wind tunnel
studies done for the Dow Chemical Company have shown, you
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259
need to have one monitoring station for every five-hundred
feet along that road in order to be sure you are really
measuring the blow away from any single point in the plant.
There is actually one monitoring station about every mile,
so there should be ten times as many monitoring stations and
more sensitive monitoring devices in order to be sure that
the amount of radioactivity coming out of the plant for a
short period of time in a single place is not exceeding
dangerous limits and endangering people downwind.
Dr. First: Do you consider yourself a scientist, Dor?
Dr. Cobb: I think that we do not need to comment on
that.
Dr. First: I ask this purposely because not all
physicians consider themselves a scientist, and I am a
little bit concerned about the manner in which you are
treating the data here. I still cannot understand how you
can state in a single sentence that there are two facts,
one, there is a million hot particles per square meter in
the soil --
Dr. Cobb: I did not say that, correction, excuse me.
I said there was an amount equivalent to a million hot
particles, and they were probably large particles.
Dr. First: And the fact there is a standard of particles
in the soil without making some connection between the two.
How does one relate to the other, can you tell me that?
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280
Dr. Cobb: I think it is fairly obvious --
Dr. First: This is a quantitative analysis, and there
is no quantitation connecting the two. The equation has not
been completed.
Dr. Cobb: The study that has to be done is to go out
to that particular piece of soil --
Dr. First: You are saying that it has not been done,
and you do not know?
Dr. Cobb: That is the whole thrust of my paper, if you
understand it. There is much research that needs to be done
before good standards can be set that we all can be happy
with.
Dr. First: Let me ask you another question then, in
your medical practice what is the certainty factor in your
prescribing of remedial measures for someone who comes to
you with an ailment, what is your factor of certainty that
the diagnosis and treatment will be --
Dr. Cobb: Oh come on, I am not a practicing physician.
I am a Professor of preventive medicine, and I do not treat
patients.
Dr. First: You are a medical person, what would you
say would be the general medical considerations of these
factors? Now you are talking in the earlier part of your
testimony about certainty and about error, and I wonder if
you have a good understanding of what these are in the
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261
context of the particular subject that we are supposed to be
discussing today?
Dr. Cobb: I presume that you, like myself, have taken
courses in biometrics and statistics in your training, and I
think our training was probably very similar.
Dr. First: I do not think so, I am an engineer.
Dr. Cobb: Well, if you have not, then maybe I should
explain some of these statistical implications here. I am
not quite sure what your question is focusing on. I would
like to be more specific.
Dr. First: Let me make it more specific then.
Chairman Mills: One more question.
Dr. First: Okay, fine. What factor of certainty or
uncertainty would you accept in this matter of setting
standards? How close should we be, how certain should we
be, even after the research is completed, understanding as
you have stated that biological organisms react in different
ways, etc., etc.?
Dr. Cobb: My feeling is that we should be as sure as
we possibly can, and this probably would involve studies
which might take several generations before we could be sure
of the lack of or presence of mutations or chromosome abnor-
malities resulting from plutonium getting into gonads; and
if we found, for example, that the rate of mutations or the
rate of chromosome abnormalities several generations from
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262
now, (in those who were descendants of those who had been
exposed) was twice the rate for those who had not been
exposed, I would think that would be a significant finding,
and this would mean that the exposure had been too high.
Chairman Mills: Dr. Garner, do you have one?
Dr. Garner: Just a comment. It is very difficult to
comment upon a paper, a presentation which is slanted to
have such an emotional appeal, but it does have some misre-
presentations in it, I would say. There is one rather
blatant one, and that is, the suggestion is there that we
are considering plutonium only as a component of nuclear
weapons. In fact, as I see it, these hearings are being
held because plutonium, whether we like it or not, is a by-
product of the use of nuclear fuel for the production of
energy, and we are concerned with the use of plutonium
itself as a nuclear fuel. What we have to do is decide
whether we want, in fact, to use nuclear energy as an
optional energy source in place of fossil fuel. We have to
decide whether we are going to do this, whether we are going
to subject people to the hazards of the use of fossil fuel,
whether we are going to deprive future generations of natural
resources by using up all the fossil fuel supplies, or
whether in fact it is better to use nuclear power and expose
people to - - I agree with you -- the not yet established
hazards from plutonium compounds. This is really the ques-
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263
tion, this is the question we are trying to decide. We have
a choice to make. What choice are we going to make? We are
not just here to talk about plutonium as a component of
nuclear weapons. That is my only comment.
Dr. Cobb: I certainly agree, and I feel the same
things that I have said should be applied and can be of
concern to the nuclear power industry, and I think that Dr,
Edward Teller's recommendation that all nuclear power plants
should be put two-hundred feet underground is a reasonable
proposal, and I would think that the same thing might be
true of Rocky Flats if we find we have to keep that plant.
Chairman Mills: Thank you, Dr. Cobb.
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264
Clarification of Testimony of Dr. John C. Cobb, with particular reference to
The questions asked by Dr. First:
I would like to amplify my emphatic disagreement with the panelists'
implied suggestion that there is no need for standards for maximum permissible
Plutonium and americium levels in the soil. This was implied by members of
the panel, in view of the existing supposedly adequate standards for air and
water.
I think Dr. First was trying to make the point that we don't know much
about the resuspension by wind of plutonium from the soil. This is certainly
true; but that does not_ mean that we could not find out what factors are
involved, make measurements under varying conditions, and then be able to make
reasonable predictions.
In regard to Denver's particular problem of wind-blown plutonium oxide
dust from Rocky Flats, the fact is that the present air-monitoring system is
inadequate to detect even rather large gusts of highly contaminated dust
blowing from the "lip area" east of the plant where 50,000 dpm/g of plutonium
alpha activity has been measured by the researchers at Colorado State
University under contract with AEC. (Ref. I)
The wind tunnel studies done for Dow Chemical at Rocky Fiats (Ref. 2)
looked into the optimal spacing of air monitors to detect plumes of contamination
coming from the plant. Their conclusion #4 (Part I, p. 37) reads as follows:
"An array of monitoring devices arranged along the north-south road which
exists to the east of the plant site should intercept plumes if they are
placed at 500 ft. intervals or closer"
This implies that monitoring stations at intervals greater than 500 ft. along
'ndiana Street could miss detection of a plume of contaminated afr coming from
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-2-
265
a point source in one of the buildings at Rocky Flats. From my study of the
map published on pg. 29 of the Annual Environmental Monitoring Report of
Rocky Flats Plant, (REP-EIMV-73), dated April 26, 1974, I conclude that the
four monitoring stations are placed approximately 5,000 to 7,000 ft. apart
along this road. That is, according to the wind tunnel studies, there would
need to be at least ten times as many monitoring stations as now exist in
order to be sure to detect a plume of contaminated air coming from a point
source. To be sure to detect a plume coming from a contaminated area
approximately 500 ft. in diameter like the "lip area", one would need moni-
toring stations at least every 1,000 ft. along Indiana Street.
What I conclude from this rough preliminary analysis is that a strong
gust of wind from the west could pick up a lot of dust from the contaminated
area and blow it past the monitoring stations in such a way that very little,
if any, abnormal rise in radioactivity would be detected. This is particularly
true because the monitors, I understand, measure only the total amount of
radio-activity accumulated over a 24-hour period. A brief gust or dust devil
containing a large amount of plutonium and seriously contaminating the
residential areas east of Rocky Flats might therefore escape detection com-
pletely by the present monitoring system.
The same wind tunnel studies addressed the problem in the Rocky Flats
parking lot where the winds are sometimes so strong (over 100 mph) that cars
need protection "from high velocity wind action assaulting vehicles with
abrasive particles..." (Part II, p. ii)
We need studies done on site at Rocky Flats under conditions of very
high velocity gusty winds and twisters or dust devils in order to find out
what is the actual situation regarding resuspension of plutonium from con-
taminated soil and how much of it is getting into the air breathed by residents
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-3-
of the area. When the winds are strong enough to sand-blast the paint and
pit the windshields of cars at Rocky Flats, I suspect we have enough piutonium
in the air to be dangerous to those who breathe it.
The present air monitoring system could easily miss detection of brief
gusts of contaminated dust, especially when the plume happened not to be
intercepted by one of the monitors. In view of the fact that piutonium dust
is already blowing loose in the uncontrolled environment, the problem of
control cannot now be solved by observing data from a few widely spaced
monitors which average over 24 hours or more. Proper standards for soil
contamination are clearly needed.
Ref. I Written testimony submitted by Prof. Lester Fraley of Colorado State
University to the Wirth-Lamm Task Force on Rocky Flats, 21 Jan. 1975.
Ref. 2 Wind Tunnel Site Analysis of Dow Chemical Facilities at Rocky Flats
Reports CER 71-72 RNM-FC-45 and CER 72-73 RNM-JAP-TGH-16 dated May
1972 and March 1973.
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267
The next speaker is Miss Susan Carpenter of the American
Friends Service Committee.
Miss Carpenter, you may proceed.
Miss Carpenter: Members of the Panel, Ladies and
Gentlemen:
On behalf of the Colorado American Friends Service, I
bring testimony today in favor of very rigorous standards
for plutonium and all transuranium elements.
-------
COLORADO
AMERICAN FRIENDS SERVICE COMMITTEE
TESTIMONY BEFORE THE
ENVIRONMENTAL PROTECTION AGENCY
January 10, 1975
Of all the changes introduced by humans into the household of nature,
large scale nuclear fission is undoubtedly the most dangerous and profound.
As a result, ionizing radiation has become the most serious agent of pol-
lution of the environment and the greatest threat to human survival on
earth .
The effects of alpha, beta, and gamma rays on living tissue are well
known. The genetic hazard is clear. The inability to reduce the radio-
activity in elements once they have been created presents an unparalleled
set of problems.
Plutonium 239, the longest lived waste product, will have to be stored
safely away for 240,000 years. In order to prevent leakage or theft for
use in atom bombs, it must be kept absolutely protected from geological
disturbances, civil strife, or enemy attack. The AEC readily admits that
the problem of radioactive disposal is far from being solved.
Contrary to common sense, the burden of proof today lies with the
ecologists; unless they can produce evidence of marked injury to people,
the change will proceed. Common sense, on the other hand, would suggest
that the burden of proof should lie with the person who wants to introduce
a change; he should have to demonstrate that there cannot be any damaging
consequences. It must be remembered that it may be many years before some
kinds of damage become evident.
The decision to build nuclear power plants rather than conventional
power plants is being based on economic considerations—will it efficiently
produce the amount of energy we need to keep pace with our public demands?
The fact that the nuclear fission represents an incredible, incomparable,
and unique hazard for human life is seldom mentioned and seldom appears to
enter into any calculation.
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269
Scientists purport to define the maximum permissible concentration
(MPc) of a given radioactive substance that the human body can be allowed
to accumulate. But it is known that any accumulation produces biological
damage. "Since we don't know that these effects can be completely recovered
from," observes the U.S. Naval Radiological Laboratory, "we have to fall
back on an arbitrary decision about how much we will put up with; i.e.,
what is 'acceptable1 or 'permissible' is not a scientific finding, but an
administrative decision."
In 1969, two scientists at the ABC's Liverpore Radiation Laboratory
called for a ten-fold reduction in the amount of radiation considered
safe for the public. These scientists, John Gofman and Arthur Tamplin,
asserted that if current limits were maintained, about 32,000 additional
deaths from cancer could be expected annually.
In addition to the above dangers, the most massive wastes are the
nuclear reactors themselves after they have become unserviceable. There
is a lot of discussion on the trivial economic question of whether they
will last for twenty, twenty-five, or thirty years. No one discusses the
humanly vital point that they cannot be dismantled and cannot be shifted
but have to be left standing where they are, probably for centuries, per-
haps for thousands of years, an active menace to all life, silently leak-
ing readioactivity into air, water and soil.
The main worry is about the future, and the international context.
FACT: On May 18th of this year, India exploded a 14-kiloton nuclear bomb,
using perhaps as little as 14 pounds of priceless plutonium Indian
scientists had secretly been removing from a small "research"
reactor built for the Indians by the Canadians in the 1950's.
(Washington Post, June 23, 1974)
FACT: "In building a nuclear weapon, the acquisition of the material is
the most difficult part." Without nuclear reactors, acquisition
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270
of materials for a nuclear weapon requires "a massive technology
far beyond the capacity of most nations." With nuclear reactors,
however/ the necessary material (plutonium) becomes readily avail-
ab1e. (The Proposed U.S.-Supported Egyptian and Israeli Nuclear
Programs, by leading reactor and nuclear weapons experts of MIT,
June 25, 1974.)
PACT: Every nuclear reactor in the world starts making plutonium the moment
its uranium fuel fissions and begins to make heat. This means that
whoever wants to make a bomb need only extract plutonium from the
irradiated wastes of an atomic power plant (which is not a tech-
nically difficult process). A plutonium bomb is the cheapest and
easiest to make. It can be built from half as muchmetal as a
uranium bomb. And it can be made by using impure plutonium.
(Washington Post, June 23, 1974.)
FACT: "A simple implosion nuclear weapon requires from 4 to 8 kilograms
of plutonium, depending on the weapon design. A medium sized re-
actor produces in excess of 200 kilograms of plutonium per year.
Accordingly, a few months operation of the reactor would produce
enough material for a number of (nuclear) weapons." (MIT Nuclear
Scient ist, as above.)
The economic prosperity of the world seems to be linked with' nuclear
energy. At the morent, nuclear energy provides only one per cent of the
total electricity generated in the world. By the year 2000, if present
plans go ahead, this will have increased to well over fifty per cent and the
equivalent of two new 500 MWE reactors will be opened every day.
If this is really going to happen, there will be a continuous traffic
of radioactive substances from the "hot" chemical plants to the nuclear
stations and .back again; from the stations to waste-processing plants; and
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271
from there to disposal sites. A serious accident, whether during trans-
port or production, can cause a major catastrophe; and the radiation levels
throughout the world will rise relentlessly from generation to generation.
Unless all living scientists are in error, there will be an equally re-
lentless, though no doubt somewhat delayed, increase in the number of
harmful mutations.
Rocky Flats Plutonium trigger plant dramatizes the case against plu-
tonium and nuclear facilities.
Rocky Flats was built in the early 50's. The plant was built without
citizen participation or education at a cost of 50 million dollars. Rocky
Flats products, plutonium triggers, are sent across the countryside to • •
assenbly installations in Burlington, Iowa, and Amarillo, Texas.
Rocky Flats' life in Colorado has been incident-filled. There have
been over two hundred industrial accidents and a major industrial fire in
1969 which caused over 50 million dollars worth of damage. . . the worst
accident in ABC history.
More than 20 million dollars worth of plutonium burned in the fire
roughly enough to build 77 atom bombs like the one that incinerated
Nagasaki. Most of the smoke was controlled in the special filtration
system; however, Denver may not be so lucky next time. The "safest"
plant in the AEC network produced the worst accident in the AEC's history.
Over 325 people have experienced radioactive contamination according
to Roger Rapoport writing in the Los Angeles Times.
Within the past two years, tritium has leaked into BroomfieId's water
supply. Plutonium found in cattle grazing near Rocky Flats exceeded plu-
tonium levels found in cattle grazing at bomb test sights in Nevada.
The unfortunate experiences of the Dow Chemical Company in operating
this plant speak for themselves. Each incident in turn: the plutonium
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272 ~5~
fire, the finding of plutonium in the dust surrounding the plant, the re-
lease of tritium into the water, etc., have increased the public's concern
and involvement. The denials, followed by admissions of mistakes and lack
of proper precautions by Dow Chemical and the AEC, have progressively un-
dermined our confidence.
The policies and people that bring Denver, Colorado, the Rocky Flats
plant and the pursuant dangers have not been responsive to the concerns
for the health, safety and continued quality of life for Coloradans. In
this conflict taking place with Rocky Flats, the AEC, and concerned citi-
zens, it appears to date that public safety is sadly the loser.
Radioactive pollution is an evil of an incomparably greater dimension
than anything humankind has known before. What is the point of insisting
on clean air, if the air is laden with radioactive particles? And even
if the air could be protected, what is the point of it if soil and water
are being poisoned?
Even an economist might well ask: what is the point of economic
progress, a so-called higher standard of living, when the earth, the only
earth we have, is being contaminated by substances which may cause mal-
formations in our children or grandchildren? Can we deal with matters of
such a basic character by means of bland assurances or official admoni-
tions that "in the absence of proof that this or that innovation is in any
way deleterious, it would be the height of irresponsibility to raise public
alarm"?
No degree of prosperity could justify the accumulation of large amounts
of highly toxic substances which nobody knows how to make safe and
which remain an incalculable danger to the whole creation of historical or
even geological ages. To do such a thing is a transgression against life
itself, a transgression infinitely more serious than any crime ever per-
petrated by people. The idea that a civilization could sustain itself on
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-6-
the basis of such a transgression is an ethical, spiritual, and meta-
physical monstrosity. It means conducting the economic affairs as if people
really did not matter at all. We call on today the EPA to
establish the most rigorous standards for plutonium and all transuranium elements.
We prefer an international panel of scientists to undertake the
extremely difficult and complex task of dismantling the nuclear arsenals--
without secrecy.
He strongly advocate the search for alternative power sources, such
as solar power, to replace nuclear power.
The Colorado American Friends Service Committee comes with a plea
for the future, as well as the present quality of life for the human family.
"The world's greatest need is an appetite for the future . . . All
healthy societies are ready to sacrifice the existential moment for their
children's future and for children after these. The sense of the future
is behind all good policies. Unless we have it, we can give nothing
either wise or decent to the world." C. P. Snow
RESOURCES
E. F. Shumacher, Small Is Beautiful, Harper and Row Publishers, 1973
Franklin Tugwell, Search for Alternatives; Public Policy and the Study
of the Future, winthrop Publisher, 1973.
Washington Post, June 23, 1974
MIT Nuclear Scientists, report reprinted in part by Another Mother for
Peace, 1974
Speech by Dr. Fred C. Ikle, Director of U.S. Arms Control and Disarmament
Agency, September 7, 1974
Roger Rapoport, "Secrecy and Safety at Rocky Flats," Los Angeles Times, 1969
Colorado Area American Friends Service Committee
2801 E. Colfax Ave., #304
Denver, Colorado 80206
388-5896
-------
Thank you.
Chairman Mills: Thank you, Miss Carpenter. Are there
any questions or comments by the Panel? Dr. Morgan?
Dr. Morgan: Miss Carpenter, I would like to commend
you as a citizen for taking an interest in this matter. I
think many of us, perhaps most of us would agree that the
burden of proof should not be with the ecologists, and
perhaps we all agree that many of these decisions, most of
them should be made by the entire society, the group in
which we live. However, I think as a university professor
and former associate with the AEC, I would like to admit
that we in the field of education have done a very poor job
in passing information on to the public. I would urge you
to continue your studies and research and not rely too much
on the Washington Post and some of these sources of infor-
mation, and I hope we in turn can provide to you more facts,
more data that you can rely upon.
Miss Carpenter: I think that would ber very helpful.
Chairman Mills: If there are no more questions, thank
you very much.
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Radiation Danger
in Denver area?
AEG asked to assist
with soil radiation guide
275
By TOM REES
Rocky Mountain News Writer
The Colorado Department of Health
Is asking the Atomic Energy Commis-
sion (AEC) and the Environmental Pro-
tection Agency (EPA) to help develop
criteria covering plutonium in soils for
use. in state and local guidelines.
The guidelines would be used m fjlf illirr re-
quirements of the state's new subdivision law.
One provision of the law calls upon boards of
county commissioners to require subdividers to
submit to commissioners an evaluation of
potential radiation hazards m areas proposed
for future land use.
The problem is that there are no existing
criteria for plutonium in soils regarding expo-
sure to the public.
Plutonium is a mar-made fissionable Iso-
tope, the use and possession of v.hirh i« regu-
lated by the AEC. Criteria fc,r (hp :-ih-iarce's
existence in air and »atrr c\o> !> i ms . i.as
ever been developed for its rirp'.rri^r n sr'l.
Just exactly what health ru.. ii"i is repre-
sented by plutonium remains unknown l>c<'ause
current standards for the radioactiv o material
are being debated by the scientific (-(immunity.
However, the National Cancer Institute consid-
ers plutonium one of the most potent cancer-
producing substances known to man.
RADIATION HAZARDS CO.VTHOVKRSY
Stung by the controversy that arose over
radiation hazards created by the use of uncon-
trolled uranium mill tailings f.; (onstrirtion
fill in the Grand Junction area. legislators this
year passed the bill requiring ounty commis-
sioners to evaluate potential udiation hazards
in proposed subdivisions,
The problem of a lack of criteria arose
when the Jefferson County Commissioners
sought State Health Department assistance in
interpreting and evaluating the new subdivision
regulation.
The problem focuses on the possible future
development of subdivisions near tne Low
Chemical Co. Rocky Flats plant Ifi miles
northwest of Denver, where land was contami-
nated several years ago by plutoruum-contami-
nated oil which subsequently was spmad. Drw,
under contract with the AEC miinujar»u"s
Plutonium triggers for nuclear weapons.
'The situation was raised at a quietly con-
ducted meeting last Wednesday among health
department, AEC an<' EPA official1;. Dr. Ed-
ward Mattel!, Boulder nuclear chemist and Dr.
H. Peter Metzger of Boulder, former president
of the Colorado Committee for Environmental
Information also were invited. Both men have
called attention to off-site contamination from
the plant. The outcome of the me«tmg wasn't
as satisfying as the state officials hoped it
would be.
The health department learned that the Na-
tional Council on Radiation Protection is work-
ins on environmental contamination. by radio-
active materials, but it's unknown if the council
is addressing itself to the problem of plutonium
in soil.
The EPA has assigned some sort of priority
to developing some general criteria for plutoni-
um around nuclear facilities. The target date
for producing the criteria is about two yean
hence
Metzger asserts that the situation goes be-
yond tne lack of criteria.
"What we learned during the Wednesday
meeting duplicated the early days of the tauV
ings problem in Grand Junction: By neglect
the AEC caused the problem in the first place.
It was left to organizations outside the AEC to
discover the problem, whereupon the AEC as-
sured the public that no problem existed. And,
If one d.rt, it wasn't an AEC responsibility.
•MAS«IVE SCRAPING JOB'
"The difference today," Metzger said, "is
that we haven't built thousands of homes over
that radioactivity yet. If we do, and years from
now it turns out that plutonium is as dangerous
as some scientists say it is, we will be faced
with another massive scraping job such as is
about to take place in the uranium milling
towns on our Western Slope."
Albert Hazle, assistant director of the health
department's division of occupational and
radiological health, said the new law. "puts the
state in the position of rendering judgment on a
situation for which there are no criteria to base
a judgment.
"In the interim we'll have to be very con-
servative. We'll submit reports to the AEC and
the EPA and ask them to help us make recom-
mendations to county commissioners. We don't
want to create another situation like Grand
Junction," Hazle said.
The AEC is seeking to- buy a wide buffer
zone around the Rocky Flats facility to sepa-
rate the plant from any other industry or hous-
ing by a mile of open space.
The Army Corps of Engineers earlier tills
week announced that it will begin negotiations
soon to purchase approximately 4,070 acres
around the plant. Funds for the purchase were
rra<]e possible by a congressional appropriation
of S6 million.
The AEC noted that the "greenbelt" also
would "provide an additional margin of safety
in the event of a plant accident which although
extremely unlikely, can't be statistically ruled
out."
Sat., Oct. 28, 1972, Denver, Colo.
Citizens Concerned about Radiation Pollution 825-2329
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Secrecy and Safety at Rocky Flats
Where does security end and obiuscation begin in the
handling of plutonium? By ROGER RAPOPORT
much oi tha
plant's safety is
substantive and how
much is empty
reassurance has
become a matter of
bitter debate
in recent yean.
The road from Denver northwest to Boulder, Colorado, is an enchanting,
20-mile drive, uncluttered by gas stations, hamburger stands or motels. At
night, when traffic is light and fierce winds howl out of the 8,000-foot
Flatirons, it can be a scary place to run out of gas or blow a tire. But more
often than not, an angel of mercy will show up behind the wheel of a pickup
truck, armed with a can of gas, the know-how to fix flats and plenty of
Western hospitality.
The men in the pickups seem anxious to be good, unobtrusive neighbors
to the 1.1 million people of metropolitan Denver. And in this way they have
something in common with the people who run a plant at Rocky Flats
nearby. But some of the reasons are different
The Rocky Flats plant is operated by the Dow Chemical Company for the
Atomic Energy Commission under a cost-plus contract. It employes 3,200
persons and its specialty is the fabrication and processing of plutonium, a
radioactive grayish metal (worth $43 a gram) created as a by-product of
nuclear reaction and the key ingredient in most atomic bombs. The plant
also repairs and replaces defective bomb and warhead components which
are sent back to it when spot checks of nuclear stockpiles turn up duds.
All this dangerous work so close to a metropolitan area has made the
plant's management, certain union leaders and the AEC sensitive about the
issue of safety, both for the general area and for the workers at the plant.
How much of the safety is substantive and how much is empty reassurance
has become a matter of bitter debate in recent years.
Plutonium is doubly hazardous to work with. Minute quantities of it
inhaled or imbedded in the skin can be lethal. It has a radioactive half-life
of 24,400 years (something that makes it imperative that any of it that gets
away not be left to lie about). Its radiation, of course, can cause permanent
damage to living cells leading to leukemia and other forms of cancer. It also
oxidizes quickly, making it a serious fire threat.
From its side of the fence, Dow and the AEC emphasize super-safety
precautions, and boast that the plant "ranks first in AEC facilities for safety
and holds the fourth best all-time mark in American indusrty—2,122
consecutive days (24,295,542 man-hours) without a disabling injury."
Rocky Flats officials ten about the elaborate safety precautions taken in
the final assembly area (buildings 776 and 777). All workers in the area
were heavily shielded and the entire plutonium assembly line with its
milling machines, furnaces and presses was enclosed in glove boxes
(ventilated, shielded enclosures) connected by conveyors. Moreover, to
guard against the accidental release of plutonium into the atmosphere, the
entire production area was sealed off inside a self-contained unit with a
special internal filtration system. An elaborate network of automatic heat
and radiation sensors plus roving teams of safety monitors guarded against
accidents.
But at 2:29 pjn. on Sunday, May 11, this fail-safe system fell through. A
fire broke out in the final assembly area. Despite the efforts of the Rocky
Flats fire department, the blaze spread through both buildings 776 and 777.
Smoke billowed so thickly that some of the firemen (wearing air tanks to
protect against radiation danger) had to crawl along exit lines painted on
the floor to make their way out.
By 5:30 p.m., when the blaze was brought under control, it had caused
more than $50 million worth of damage. The worst accident in AEC
history, the fire put the final assembly area out of commission and forced a
halt in Air.^L ui nuclear missile products. .-»* part of the year.
Potentially, the disaster was the biggest step the United States has ever
taken toward nuclear disarmament. More than $20 million worth* of
plutonium burned in the fire — roughly enough plntonium to build 77 atom
bombs like the one that incinerated Nagasaki.
But rather than signal Geneva, Congress quickly shelled out $45 million
in supplemental funds to clean up the mess, a figure equal to the entire
fiscal 1969 Rocky Flats budget. Now 240 Rocky Flats regulars and 60
summertime college students are sifting through charred debris to recover
the burned plutonium. Meanwhile hundreds of railroad cars will ship
330,000 cubic feet of radioactive wastes to AEC burial grounds in Idaho.
Anxious to understand how the ABC's safest plant could produce its
worst disaster, I paid a visit to Rocky Flats recently. I learned that despite
the vaunted precautions there have been over 200 small fires since the
nuclear weapons facility opened in 1953. Recently, fires had been occurring
about once a month in the buildings where the $50 million blaze took place.
But on the Sunday afternoon the disaster started, only one ventilation
system operator was in the building. Says Rocky Flats General Manager Dr.
Lloyd M. Joshel: "I think we're going to have to review our monitoring
procedures in this area."
All this has led local scientists to ask Rocky Bats officials if they
shouldn't also review the possibility of moving their plant away from
Denver. The Denver scientists are worried even though health surveys show
that there was no release of plutonium from the plant site during the fire.
Most of the smoke was trapped by the special filtration system.
Denver may not be so lucky next time.
Even the clean-up of the May 1 1 fire is causing more trouble. On July 30
two plastic bags surrounding a can containing some of the plutonium
recovered from the $50 million blaze caught fire. Two workmen in the area
were contaminated.
Their names are only the latest addition to the roster of more than 325
workers who have experienced radioactive contamination at the plant.
Officially, AEC spokesmen say there have been a mere 21 disabling
injuries and one fatality since the plant opened. But they refuse to disclose
the number of workers who have received their maximum permissable dose
of radiation and been transferred to cold (non-radioactive) sections of the
plant. The local union is not allowed to see medical files of contaminated
workers or make an independent investigation of plant accidents.
Perhaps the biggest question looming over Rocky Flats is the number of
workers who have cancer or have died from it. Dow public relations man
Mike Carroll says "It would not be discreet to discuss this. I've got the
^^^
••he
May 11 fire was
the biggest step the
VS. has taken
toward nuclear
disarmament The
plutonium that was
burned was roughly
enough to build 77
atom bombs like the
one that incinerated
NuycucndL
figures but I won't give them to you."
One known cancer victim within the plant is 60 year-old Everett
Holloway, an inspector with terminal leukemia: "I started checking into my
medical records at the plant to see if I could establish some compensation.
But I discovered that the company has lost some of my quarterly urine
sample reports (which are taken to measure radioactive contamination). I
was told that there was nothing the company could do for me until I become
completely disabled. Supposedly they have switched me into a cold area
but they're still machining a lot of radioactive material hi my area and I
don't know what effect it will have on my condition. 1 can't afford to quit
because when a 60-year-old man like me comes asking for a job they look
at you like you're poison."
Of course no one saw the plant as a liability when it came to Denver in
1953. Geographically, the rocky cow pasture 25 miles northwest of Denver
was a smart choice because it was close by Colorado University in Boulder,
skilled manpower in Denver and attractive recreational opportunities in the
mountains. The plant soon grew into a crucial link in the AEC nuclear
weapons complex
In all, the bomb work was divided between eight AEC facilities. Design
-------
u I research and testing was done at New Mexico and California plants. Rocky
Hats was responsible for plutonium components, the Kansas City plant
made electro and electro-mechanical components, a Dayton, Ohio, plant
made detonators and a plant in St. Petersburg, Fla., made neutron
generators. These parts were assembled into nuclear weapons at plants in
Burlington, Iowa, and Amarillo, Texas.
In the late 1950s, the plant mushroomed and radiation hazards grew with
it. Between June 14,1957, and October 28,1958, there were 24 documented
fires, explosions, plutonium spills, and contamination incidents at the plant.
Testimony by Rocky Flats union leaders and government officials at AEC
radiation hazard hearings in Washington during March, 1959, detailed many
of the accidents; among them were serious fires in June and September of
1957.
lerhops
the biggest question
looming over Rocky
Hots is the number
of workers who
bore cancer or have
died from it. A Dow
spokesman says it
' vrould not be discreet
to discuss this.
Rocky Flats union leaders were particularly concerned about
management's reluctance to bring in health physicists (who supervise
worker health) after serious accidents took place. For example they testified
that on October 28, 1957, a "chip fire in a production area occurred and as
usual health physicists were not notified. No air samples were taken nor
were any respirators worn to guard against inhaling dangerous plutonium.
Health physicists learned of this operation after a worker involved in it
coughed up black sputum at his home and became thus concerned with the
method in which the incident had been handled by his supervisors."
The union leaders also pointed out that on September 4, 1958,
supervisory personnel instructed workers to clean up a radioactive
materials spill "using no respirators and without health physicists being
informed of the situation." Subsequently, health physicists were notified, and
recommended respirators and "area supervision gave in and allowed the
workers to wear them on subsequent cleanup operations of the spill."
On October 3, 1958, another supervisor "stopped health physicists from
allowing the men to know what the airborne contamination was in their
production area on the grounds that it was his business only as to what the
level was."
A variety of serious contamination incidents were also reportedly in
supposedly cold areas. For example, on September 10, 1958, a "cafeteria
survey showed 50 to 54 smears (taken to measure radiation) to be over
allowable tolerance level." Ninety-seven of 99 smears in the locker room
also showed contamination. Radioactivity was also found on drinking
fountains, sinks, laundered caps, shoes, drums, flasks, carts, lifts and saws
in cold areas.
•' As health hazards increased some workers were disappointed to see
''inodification of some safety procedures. For example, prior to March, 1961,
health physicists checked all employees out of hot areas with an alpha
counter to make sure they were not carrying excessive radiation. But after
'March, 1961, workers were given more discretionary authority to monitor
themselves out of hot areas.
j Then and now, Rocky Flats officials felt that national defense precludes
public discussion of these matters. But in the meantime they have been
quietly documenting their problems in articles for the scientific community.
Tor example, in 1964, Rocky Flats health physicists S. E. Hammond and
E. A. Putzier had this to report in the sober international journal Health
Physics:
"The Rocky Flats wound counter was developed in 1957 to measure the
amount of plutonium contamination present in wounds incurred in process
areas. Since that time more than 900 wounds have been monitored of which
nore than 300 have indicated some degree of plutonium contamination
. . The material is completely removed when possible. However, in cases
.vhere the plutonium is deeply imbedded or where physical impairment
might result from complete excision, small amounts of plutonium may be
left in the wound."
By 1965 union officials felt it was time to make a strong pitch for a new
safety package in their contract negotiations with Dow. They asked for a
joint "Radiation Safety Committee" with the company that would meet bi-
monthly "to discuss problems arising from radiation safety complaints from
any employees." They also proposed adding three union members to the
company's Executive Safety Council and making radiation records of all
employees available to "the union at least once each year in writing." All
the proposals were rejected by management.
By 1967 it was becoming clear to Health Physics readers that the
situation at Rocky Flats was getting worse. In an article titled "Evaluation
of Lung Burden Following Acute Inhalation Exposure to Highly Insoluble
Pu02 (plutonium oxide)," J. R. Mann and R. A. Kirchner of the Rocky
Flats staff reported that "On 15 October 1965, a fire in a plutonium
fabrication plant resulted in a large-scale spread of plutonium oxide. The
Rocky Flats body counter (a device that measures radioactivity in the body)
was used to measure the plutonium in the lungs of all employees working in
the area. Of approximately 400 employees counted, 25 were found to have
enough plutonium in their lungs to deliver a dose of 15 rem/year. (In line
•with federal radiation standards Rocky Flats generally tries to keep worker
exposure under 5 rem/year, although a complicated formula permits
special exceptions.) On the average, 30 percent of the material initially
deposited was cleared in 2 to 3 months. The remaining material is clearing
very slowly with little or no measurable absorption into the bloodstream."
In another 1967 Health Physics article, C. R. Lagerquist, E. A. Putzier
and C. W. Piltingsrud of the Rocky Flats staff described the gradual
amputation of the thumb and second finger of a worker injured by the
"explosive reaction between hot plutonium metal and carbon tetrachlor-
ide." They wrote that eleven months after the amputation "it was thought
that there was a high concentration of plutonium in a small portion of the
remaining thumb stump." But the operation was only a partial success and
six months later "the remaining portion of thumb was removed."
Dissident members of Rocky Flats Local 15440 of the International
Union of District 50 of the United Mine Workers finally'got a little of the
safety story out into the open in late 1967. At the time the coal-conscious
international leadership of the United Mine Workers was conducting a
vigorous campaign against a proposed nuclear power plant at Platteville, 30
miles north of Denver. Spearheading the campaign was the Ralph Nader of
the atomic energy industry, a United Auto Workers official named Leo
Goodman.
As Secretary of the Atomic Energy Technical Committee of the AFL-
CIO, Goodman had served as a consultant to unions working in atomic
energy and proved a nemesis to the AEC.
His files suggest about 6,000 Western states uranium miners are now
dying of cancer. He also points out that there have been 1,400 known
accidents in atomic plants and 200 known cases of cancer. Naturally these
statistics are useful to the United Mine Workers in their fight to protect coal
power and guard against the inherent dangers of nuclear power.
So in November, 1967, Goodman joined UMW leaders in a trip to Denver
where they worked to block the proposed atomic power plant at Platteville.
After reading in a Denver paper that Goodman was in town, a group of
Rocky Flats employees visited him at his motel room. They told the atomic
hazards expert that safety was deteriorating rapidly in their plant, and
reviewed case histories of workers who had contracted cancer and then
been denied medical pensions. Reporters for the United Mine Workers
Journal and Cervi's Journal, a muckraking Denver business weekly, were
present and published accounts of the meeting. To the chagrin of Dow
officials and leaders of Rocky Flats Local 15440 of District 50 of the UMW
T
lh«
risk* of atomic
power axe to bad
insurance companies
will not Mll policies
ior reactors. Only
a special act of
Congress provide*
$500 million worth
ol insurance Sot
atomic power plants.
-------
the stories pointed out that "Officials of District 58 of the UMW
representing the Dow Chemical workers will not discuss the radiation
dangers involved for workers at Rocky Flats. If they do, they face loss of
their security clearance."
This story ignited a feud within the UMW. International Leaders of the
UMW were already sore at District 50 (with a regional office in Denver)
because it refused to join their fight against the proposed atomic plant at
Platteville. After the stories on the meeting with Goodman were published,
District SO officials went out of their way to back the new atomic plant. In
February, 1968, a delegation of Rocky Flats local 15440 leaders headed by
President Jim Kelly traveled to Washington for a regional directors
conference of District 50. Aided by their Denver regional director Sam
Franklin, the Rocky Flats union leaden extolled the virtues of the safety
program at their AEC plant. Using color slides provided by the Rocky Flats
management they showed how "the Rocky Flats plant has achieved one of
the world's best safety records . . . through a highly effective program of
industrial safety." They pointed out that "The design of Rocky Flats
facilities insures that each worker's exposure to radiation is kept to a
minimum . . . The average work-related exposure of a Rocky Flats em-
ployee for an entire year is barely above the radiation, received during a
chest x-ray . . ." Gene DeCarlo, chairman of the union's radiation
committee told how "all employees are particularly careful about cuts and
scratches on their flesh as the radiation danger increases in an open flesh."
According to District 50's Denver Regional Director Sam Franklin, the
assembled directors "were so impressed by the presentation that they
subsequently passed a resolution calling for the expansion of District 50's
ristrict
SO was accused of
being willing 'to risk
the lives of •very
dtaxen in the country
in potential nuclear
natcto? accidents for
the sake of a few.
role in the atomic power industry."
Back at Rocky Flats, workers soon received news of the meeting in the
February 26, 1968, editionxrf District 50 News. In the lead story it was
reported that District 50 International President Elwood Moffett declared
that "District 50's future is 'clearly interwoven' with the progress and
development of the atomic energy industry." Further, the International
Executive Board of District 50 promised to "continue to represent and
safeguard our membership employed in every phase of that industry . . ."
The paper also carried the text of District 50's resolution endorsing
atomic power plants "... contrary to the thinking of those who
sporadically would remind us that progress in the field of nuclear energy
represents a destructive force which could annihilate humanity . . .
mounting scientific statistics amassed through the 2,000 man-years of
experience in the Atomic Industry discount this pessimism."
Rep Chet Holifield, chairman of the Joint Committee on Atomic Energy,
inserted the District 50 resolution into the Congressional Record. Beneath
the Holifield story in the March 11, 1968, News issue was a Freudian slip
of a filler that did not amuse the Rocky Flats workers' "1.4 million
Americans now alive have been cured of cancer. Early detection and
prompt treatment saved their lives. The American Cancer Society urges you
to become familiar with cancer's seven warning signals and to fight the
disease with a checkup and a check," it read.
The international leadership of the United Mine Workers was also not
amused by District SO's endorsement of atomic power at the expense of
coal. In March, 1968, the UMW International expelled District 50 charging
that it was "willing to risk the lives of every citizen of this country in
potential nuclear reactor accidents for the sake of a few members they
have in atomic plants."
Since the break, District 50 has been getting along better with Dow and
worse with the UMW. In March, 1968, just after District 50 endorsed
atomic power, one of its biggest locals, 12075 in Midland, Mich, set a
"chemical industry precedent" by winning an 80-cent-plus, three-year
package from Dow. This paved the way for a 60 cent-an-hour direct wage
hike plus a wage reopener in the third year for Rocky Flats Local 15440.
The iatter contract was ratified in June, 1968. But Local 15440 again lost its
-------
the union leaden by phone md they say Sen. Keonedy'i staff it trying
to let up • meeting In Wtthlngton for mid-September.
But even ihould the meeting eome off, the Q clearance may well save the
day for the AEC. For the Q clearance U the real barrier to the truth about
Rocky Flati. Ostensibly Invoked to protect the national drfense.lt U really
UMd by plant oflidali for telf-deTente. The Q clearance It the nation'*
higbeit security claiiification and explains why every Rocky Flat* employee
down to janitor if reluctant to discuss plant safety. For violating security
can coit an employee his clearance, job, and pension u well ai leave him
open to federal prosecution. In the end, though, thli illence may be
ihattered by diiatter
The May 11 fire hai led the Colorado Committee for Environmental
Information, a group of icientistt from collegei and induttriei in the area to
voice "real concern for the health and safety of Colorado citizen* because
of possible accidents involving large quantities of radioactive chemical! at
Rocky Flats, located in the rapidly growing metropolitan area between
Denver and Boulder."
Rocky Flats officials are not oblivious to this fear themselves. The AEC's
Mike Sunderlind, who has been with the plant since it opened, keeps a thick
civil defense manual nearby at all time: "If some plutonium smoke went up
we'd call all the police agencies, tell them which way the smoke was going
and ask mem to move everybody out of the path. Afterwards
decontamination teams would have to scrape all the plutonium off
everyone's roof)—it would take months. Then we'd have to bring in all
the people and put them through our one body counter (designed to
measure radiation). It would be one hell of a mess."
The AEC is particularly anxious to minimize fears about atomic power,
and with good reason. At this writing, there are 15 American atomic power
plants in operation,31 beingbuilt and 42 in the planning stage. Several have
had serious accidents and two good new books The Careless Atom, and
Perils of the Peaceful Atom, document the hazards. One accident in
Michigan endangered the lives of 133,000 people. After a 1957 accident at
the Windscale Works breeder reactor in England, authorities had to seize
all nulk and crops within 400 square miles of the plant. And a 1957 AEC
survey shows that a reactor built 30 miles from the nearest city could kill
3,400 people, injure 43,000 and came $7 billion damage in a bad accident.
The risks of atomic power are 10 bad that insurance companies win not sell
Copyright (c) 19b9 Roger Rapoport -
first appeared in The Los Angeles
Times.
poUdei for these reactors. Only a
•pedal .act of Congress provides
$500 million worth of insurance for
atomic power plants and abeolves
them for liability over that amount.
Thus • panic In Denver over
Rocky Flats could jeopardize the
future of the entire atomic energy
industry. For if the public figures
out that nuclear war U not Inevitable
and nuclear accidents are, the ABC
Is in trouble. Of course the ABC
does its best to discourage this kind
of thinking. When I first started
work on this story, the AEC made a
special effort to dissuade me from
visiting Rocky Flats. After I insisted
on taking a look, I was accompanied
by three p.r. men (one flew in 400
miles from Albuquerque; another
was an FBI agent) who shadowed
me into toilets and wouldn't let me
within 100 yards of the firesite.
Geo-4e Dennis, the AEC man who
came in from Albuquerque (his
office governs Rocky Fiats) pleaded
with me "Not to give any of our
secrets away to the Russians."
At a time when six nations have
atom bombs and most high school
physics students know the basics of
atom bomb making, it seemed like
he was really trying to invoke old-
fashioned patriotism to keep AEC
secrets from the Americans. After
faith for their safety. Responding to
public concern, Colorado Governor
John Love arranged for a private
briefing on the fire with Brig. Gen.
Edward B. Oilier, director of the
ABCs military applications divi-
sion. In an Interview with Wist,
Oov. Love indicated he found the
AEC reassuring: "They teemed to
be quite certain no radiation es-
caped from the plant site during the
fire and will take precautions to
make sure this kind of thing doesn't
happen again. If you've got to have
nuclear devices in the country I
guess you might as well have the
work done here as any place else."
But at a time when the United
States has enough nuclear weaponry
to wipe out the world several times
over, one wonders what Rocky Flats
is doing with enough plutonium to
make at least 77 Nagasaki size atom
bombs. While cleanup crews put the
final production area back together
Rocky Flats is moving ahead with a
$75 million dollar expansion pro-
gram. Some critics feel this is the
wrong direction in the wake of the
AECs worst disaster. Says UMW
atomic consultant Leo Goodman:
"Now's our chance to get together
with the Russians and ban nuclear
weapons together. It win save us a
lot of money and be a lot safer."
lliiKe«ilr
hagood war of toping
problem Hk» leukemia
qtObaaciflnaifa
ttwfanflr.TtwAICwffl
mote 17^00 Q eUorane*
talWO.
all, the AEC ii spending a record
$7,891,000 on Q clearance investi-
gations of 17,300 personnel In fiscal
1970. Each investigation takes
several months and one middle-aged
Rocky Flats worker told me that
"When they investigated me they
went all the way back to my first
grade teacher and she was 84."
Apparently the ABC is getting its
money's worth. For security is a
good way of keeping problems like
leukemia, plutonium spills, and $50
million fires in the AEC family.
Veteran Rocky Flats employees
confess they still don't know what
really happened on May It: "Nor-
mally they have 8 to 10 guys
patrolling those buildings for fires
and radioactive contamination.
Either they were playing around
with something they don't want to
admit to or they're guilty of die most
incredible safety blunder I've ever
heard of. If you had fires regularly
in a building wouldn't you keep
people on guard?"
In the end, the plant work force
and the people of the Denver area
are dependent on the AECs good
But this is only wishful thinking.
Clearly the AEC will continue
running the plant; paying the
salaries, regulating security, deter-
mining health standards, monitoring
radioactive leaks and investigating
accidents. Question] about deterior-
ating safety conditions, accidents
and worker health will remain
unanswered. For Dow officials are
beholden only to the AEC.
As criticism has grown there has
been a predictable reaction inside
the plant. Rocky Flats General
Manager Dr. Lloyd M. Joshel
inserted a brief message in his house
organ Dow Newsline to remind
employees that silence is golden:
"We are facing a difficult situation
as a result of the fire May 11.
Certain uninformed people have
questioned the value of our presence
here and have attacked the integrity
of both the AEC and Dow. It is hard
not to make an angry rebuttal, but I
hope each of you will help our
efforts to solve this problem by not
commenting on the situation either
by letters or by discussions off the
plant site." (f
-------
Note;
Miss Carpenter also submitted an article titled "Project
Gasbuggy and Catch-85" by Peter Metzger printed in The New
York Times Magazine. It is not reprinted here because a
copyright release was not obtained.
Also, an article by George Wald titled "Arise, Ye Prisoners"
was submitted. It is reprinted after Dr. Cobb's testimony.
281
-------
282
Chairman Mills: We have one other speaker before
lunch. If we could get Dr. Eric Eisenbud from the Lutheran
Hospital here in Denver.
Dr. Eisenbud: My name is Eric Eisenbud and I am an
emergency room physician in the City of Denver.
-------
283
In my mind the EPA's role in educating the American
public about pressing environmental issues has perhaps been
underutilized. For example, I would like to know the
specific ways in which the citizens of Denver were informed
about this very hearing. I suspect that if this hearing
were publicized, EPA should not take the major credit.
I would like the EPA to consider the various types of
accidental release of radioactivity in the environment. The
subject of accidental release of plutonium oxide from Rocky
Flats is adequately covered by other speakers here today.
Other no less dangerous possibilities are nuclear power
plant accidents, the so-called acts of God, and transporta-
tion accidents involving nuclear materials. This discus-
sion, however, centers upon the situation of nuclear theft.
Many of the ideas I present are thoroughly elucidated in Dr.
Theodore Taylor's recently published book, Nuclear Theft,
Risks and Safeguards.
Specific information about how to construct a nuclear
bomb was officially declassified in 1954 under President
Eisenhower's Atoms for Peace Program. The critical mass of
plutonium oxide needed to construct a crude atomic bomb is
approximately 10 kg. Similar amounts of uranium 233 and 235
should also be suitable for a bomb. According to Dr. Taylor:
"Under conceivable circumstances, few persons,
possibly even one person working alone, who
-------
284
possessed about 10 kg. of plutonium oxide
and a substantial mass of chemical high
explosive could, within several weeks, design
and build a crude fission bomb... that...would
probably explode with the power of at least
100 tons of chemical high explosive."
Furthermore, Taylor states that a nuclear explosion
with a yield of only 10 tons in the center of a football
stadium during a game could lethally irradiate 100,000
spectators.
Moreover, according to a special study completed last
April by the AEC, "the potential harm to the public from the
explosion of an illicitly made nuclear weapon is far greater
than any plausible power plant accident..." (N.Y. Times,
December 29, 1974). Indeed, the dispersal of a few grams of
plutonium stolen from a nuclear fuel facility into the
ventilation system of a large office building could kill
most of its occupants.
Everyone is aware of the proliferation of world
terrorist groups and activities in the past several years,
and the possibilities of political blackmail through the use
of crude atomic bombs are numerous. Let us briefly evaluate
the risk of nuclear theft. It is essentially a function of
the safeguards that exist in the nuclear industry today,
and of the willingness of a person or group to steal nuclear
material and to make nuclear threats. The New York Times
reports about an unnamed Federal official who stated that
-------
285
there have already been two instances when Government
employees were discovered to have stolen enough nuclear
material to build a nuclear bomb. Also, a highly placed
official in the Atomic Energy Commission said one of its
plants was unable to account for about 9,000 pounds of the
highly enriched uranium it had produced since the plant
began to operate. Finally, according to another AEC official,
there have been several occasions in the last two years when
Government agencies received plutonium bomb threats. (N.Y.
Times December 29, 1974).
As for safeguards, praise is conspicuously lacking from
all but the AEC itself. The Newsletter of the National
Resource Defense Council (summer/fall 1974) states that a
General Accounting Office report on November 7, 1973, docu-
ments that two of three licensed fuel plants it inspected
had conditions "which significantly limited the license
holders' capability for preventing, detecting, and respond-
ing to a possible diversion or diversion attempts of special
nuclear fuels." The same plants were given a GOOD evalua-
tion by the AEC. Somewhat earlier in 1973, the GAO had
reported about security measures at nine nuclear power
plants:
"At several plants we visited, we noted
unlighted protected area perimeters, unlocked
outside doors, lack of intrusion alarms and
unarmed watchmen." (N.Y. Times December 29,
1974)
-------
286
Dr. Taylor went to compulsive lengths to evalute the
various steps in the nuclear fuel cycle which are particu-
larly vulnerable to theft, and found six areas where a
single person could conceivably steal enough uranium or
plutonium to make a crude nuclear bomb. He explains that
there are several factors at the root of the inadequate
safeguards:
1. The unwillingness of the AEC to seriously consider
the possibility of a sophisticated armed attack on a nuclear
facility or on nuclear materials in transit.
2. Lack of uniform and enforced regulations for the
industry.
3. Lack of any critical feedback on the AEC from the
public or from another governmental agency.
4. Both nonexistent public knowledge and superficial
congressional knowledge of present deficiencies in safe-
guards .
5. Paucity of adequate monetary allocation for the
areas of safeguards. Only $10-million dollars was expended
in 1974 for the entire nuclear industry for safeguards.
An essential point is that if present safeguards are
not significantly strengthened now, then the planned eight-
fold expansion of the nuclear industry and of existing
plutonium stockpiles by 1990 will increase the risk of
-------
287
nuclear theft exponentially.
An informed American public, not a handful of individuals
from the Nuclear Energy Commission, should be given the
right to make an educated decision about the risk of nuclear
theft that they are willing to tolerate and about the type
of safeguards that technology is capable of offering at this
time.
I close with some questions for the EPA:
1. Does the EPA recognize that nuclear theft and its
various forms of possible environmental contamination should
be a major concern of the agency?
2. Is the EPA willing to undertake a more vigorous
role than it has thus far in educating the American Public
about this and other environmental threats?
3. Should not the AEC be directly accountable to the
EPA with regard to such important matters as nuclear safe-
guards, particularly instances of transport of nuclear
material between facilities?
Chairman Mills: Are you proposing these to the EPA in
terms of receiving an answer?
Dr. Eisenbud: Yes.
Chairman Mills: In which case, we will respond to
that. I will not attempt to clarify these issues at the
moment.
Are there any questions by the Panel?
-------
288
(No response.)
Chairman Mills: If not, we will stand in recess until
2:00
(Whereupon, at 1:00 p.m., a luncheon recess was taken.)
-------
ENVIRONMENTAL PROTECTION AGENCY
289
JAN 2 3 1975
Dr. Eric Eisenbud
Lutheran Hospital
8300 West 38th Avenue
Denver, Colorado 80212
Dear Dr. Eisenbud:
I an responding to the questions at the end of your testimony
giveu at the recent Public Hearing in Denver, during which I informed
you that I would do so.
Question 1; "Does the EPA recognize that nuclear theft and its
various forus of possible environmental contamination should be a.
major concern of the agency?"
Response; "tea, EPA is concerned with the question of safeguard
of nuclear materials. However, the primary responsibility for this
activity resiuea, and in our opinion should renain, with the former
Atonic Energy Commission and its successor agency, the Nuclear
Regulatory Commission. For your information, I au enclosing a copy
of ETA's comments on the draft "Generic Environmental Statement Mixed
Oxide Fuels for Recycle Plutonium in Light Water Cooled Reactors,"
which conveys the Agency*s opinion on this subject.
Question 2; "Is the EPA willing to undertake a more vigorous
role than it has thus far in educating the American Public about this
and other environmental threats?"
Response; My answer is No, because your question implies that
EPA is not fulfilling its role concerning nuclear energy and its
various ramifications. 1 believe the record of EPA attests to the
fact that we are, in fact, fulfilling, our responsibility already in
a vigorous manner.
-------
290
Question 3; "Should not the flEC be directly accountable to the
EPA with regard to such Important matters as nuclear safeguards,
particularly instances of transport of nuclear naterial between
facilities?"
Response: No. We have, in this Agency, spoken out on natters
involving nuclear energy and will continue to do so. He are respon-
sible for providing radiation protection guidance, for the promulga-
tion of "generally applicable environmental standards," for technology
assessment, including major reviews of environmental impact statements,
and for such environmental monitoring as necessary to determine the
"state of our environment." These responsibilities, however, do not
and should not include direct responsibility for the safeguard program.
EPA has responsibility for overseeing radiation protection on a
national scale and does not need to be actively involved in the day-to-
day regulation of nuclear facilities.
Sincerely yours,
William A. Hills, Ph.D.
Director
Criteria & Standards Division (AW-560)
Enclosure
cc: Paul Suith, Region VIII
A.J. Hazle, CDH
bcc: Dr. Augustine
Mr. Harward
Hr. Weaver
Dr. Burley
-------
29'
AFTERNOON SESSION
Chairman Mills: I would like to get started. I see
that one of the Panel members has not arrived, Dr. First.
He will be here shortly.
I think I should make a few opening comments for those
who were not here this morning. The purpose of this hearing
is to attain information relative to the setting of stand-
ards for plutonium and transuranium elements, and in that
regard we hope that the information that we get is relevant
to that particular question and would be within the scope of
that. There are many issues having to do with nuclear power
and activities which may or may not be involved with the
establishment of plutonium standards, so I would ask those
who have presentations this afternoon and this evening, as
far as we need to go, to keep that in mind so we can move
along.
There have been a few additional requests to give
presentations, and I would say that those would follow the
agenda that we had already established. That is, if one was
willing to stay around until the last speaker on the agenda,
then, we would try to accommodate those individuals.
We will move along. Our next speaker is Dr. Donald
Geesaman from the University of Minnesota. Dr. Gessaman?
Dr. Geesaman: First, I am not a doctor, I am a pro-
fessor, but not a doctor.
-------
-------
TESTIMONY CONCERNING THE ACCEPTABILITY
OF EXISTING PUBLIC HEALTH
GUIDANCE FOR PLUTONIUM
Donald P. Geesaman
School of Public Affairs
University of Minnesota
Minneapolis, Minnesota 55455
January 10, 1975
(Statement presented at the public
hearing on plutoniurn standards
held by the United States Environmental
Protection Agency in Denver, Colorado
on January 10, 1975. The material of
that oral presentation is annotated
and expanded here.)
-------
294
Referencing is deliberately minimized in this
testimony. The reader is referred to the attached
Appendices, which are the basis for much of the
testimony, and which have detailed referencing.
-------
295
PERSONAL DESCRIPTION
My name is Donald P. Geesaman. I reside at 815 Heinel Drive,
St. Paul, Minnesota. I am an Associate Professor in the School of Public
Affairs of the University of Minnesota (Minneapolis). My principal
research interest is the relationship between policy and technology with
particular emphasis on nuclear technologies.
I am a citizen of the United States of America. I was born on
February 12, 1933 in Fort Calhoun, Nebraska. I am a theoretical physicist
by training. I was employed for 13 years at the Lawrence Radiation
Laboratory (Livermore) of the University of California, where from 1960
to 1966 I was a member of the Theoretical Physics Division, and from
1967 to 1973 I was a member of the Biomedical Division. (The Lawrence
Radiation Laboratory is a nuclear research laboratory operated under
contract for The Atomic Energy Commission by the University of California.)
While in the Biomedical Division at Lawrence Radiation Laboratory my work
was primarily concerned with analysis of the hazards associated v/ith
nuclear technologies. In September of 1973 I joined the faculty of the
School of Public Affairs at the University of Minnesota (Minneapolis).
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296 SUMMARY
Plutonium is an effective radiological carcinogen in laboratory
animals. Alpha-emitters, such as plutonium, are proven generic carcinogens in
man.
The mechanisms underlying the origins of cancer are poorly known.
Radiation-induced carcinogenesis is no exception.
Present standards for plutonium are based on the assumption of a
\
uniform exposure by the material. For exposures by plutonium particulates,
such an assumption is manifestly erroneous; and as a basis for making public
health evaluations associated with particulate exposures, the assumption may
be far from conservative. Human experience with plutonium exposures is
insufficiently documented to provide meaningful support for existing standards.
Radiation exposures of tissue by plutonium particulates are notably
inhomogeneous, diverse and complex. The concern is that amongst that
considerable diversity, unrecognized resonant situations may exist with anomalously
large carcinogenic responses which dominate the overall hazards associated with
exposure. An animal experiment, such as Albert's, demonstrates the existence
and hence possibility of such a resonance; others may exist. Scientifically
respectable hypotheses can be developed around their existence; the disruptive
particle hypothesis was so conceived.
If plutonium becomes a common element in commerce, the standards
specifying its control acquire profound public health significance. Beneath
the determination of those standards is the judgment of how scientific
uncertainties relate to public health decisions. Considering the gravity of
the decision and the imperfect knowledge on which this decision must be
grounded, I would suggest that a proper basis for establishing plutonium
standards is the most conservative hypothesis consistent with scientific
experience. For this basis the hot particle hypothesis or the Martell
hypothesis commend themselves for careful consideration.
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297
STATEMENT
I consider it a privilege to testify here today. I have no fondness
for giving testimony but I have paid my way here to appear because of what
I consider a historical obligation to see through an issue which I helped
to raise several years ago, and which I consider to be pertinent to your
deliberations. I will be historical in my presentation. In that way the
material and perspectives presented will be more meaningful to me. Most
of what I have to say derives from concepts formed in the past at a time
i
that I had formed no strong bias against nuclear power.
* * *
Shortly after joining the Biomedical Division of Lawrence Radiation
Laboratory (Livermore), I was asked to assess the potential ,public health
hazards associated with plutonium aerosols. Consequently, in February 1968
I published "An Analysis of the Carcinogenic Risk from an Insoluble
Alpha-Emitting Aerosol Deposited in Deep Respiratory Tissue" (included as
Appendix I). I quote some conclusions from the analysis in that report:
"While no realistic evaluation of the total carcinogenic
risk is accomplished, the results are such as to '•*'
clarify the nature of the problem. In partifcular,
if the loss of mitotic competence by a local cell
population is sufficient to guarantee no origin of
cancer within that population, then the carcinogenic
risk from particulate sources does not scale to the
total energy dissipated. To say what dose characteristics
are significant to the risk would require an accurate
knowledge of'clearance, local shielding responses,
and the mechanisms of cancer induction. In the
absence of this detailed knowledge the suggested
course is an experimental determination of the number
of source particles per induced cancer."
and
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298
"The particle problem is unique in that: (1) there
is enormous variation in the dose level and dose
characteristics to 'which different cell populations
may be exposed, and (2) volumes involved are small
so that disruptive doses are not necessarily organ
fatal. Implicit in the problem is considerable
diversity, and I would be concerned that somewhere
in this diversity are unanticipated resonant
situations where the risk is large compared with
predictions made from linear dose effect relations.
"The risk does not scale with the total energy from
a source, and with present knowledge it is
precarious to try to describe in a detailed way
the relationship between radiation level and
carcinogenic tissue response. It v/ould Seem that
the most reasonable and hopeful approach is to
attempt an experimental determination of the number
of cancers per source particle as a function of
source strength at relatively low tiss,ue burdens.
With this, a meaningful estimate of risk would be
readily accessible."
Subsequent to that report 1 reviewed experiments involving skin and lung
carcinogenesis in mammals after intense localized doses of ionizing radiation.
As a result of this analysis I published an addendum to the original report
(included as Appendix II). There I reached the following conclusions:
i
"Summing up, intense radiation exposure of
mammalian skin and lung tissue commonly results
in cancers. Tissue injury and disturbance are
a primary consequence of intense radiation insult,
and are observed in association with carcinogenesis.
Albert has exhibited a simple proportionality
between skin carcinomas and atrophied hair follicles.
No general description of precarcinogenic injury
exists, but in a crude .souse; Lhe available
observations are compatible with the idea of an
injury-mediated carcinogenesis. Cancer is a
frequent instability of tissue. Since tissue
is more than an aggregate of cells, and has a
structural and functional unity of its own, it
would not be surprising if some disrupted local
integrity, a disturbed ordering, comprises a
primary pathway of carcinogenesis. The induction
of sarcomas with inert discs of Mylar, cellophane,
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and
1 299
Teflon and Millipore (Brues el aj_.) is indicative
that such a mechanism exists.' Presumably mitotic
sterilization is an important factor in any
carcinogenesis mediated by radiation-induced tissue
injury. The functional relation of this factor to
the carcinogenic response may be quite different
from a linearity in the surviving mitotic fraction.
"While regrettably unquantitative, the hypothesis
of an injury-mediated carcinogenesis is suggestively
descriptive. If the respiratory zone of the lung
contains a structure analogous to the irat hair
follicle, and if a radioactive particulate deposited
in the respiratory zone has the capacity to disrupt
one or mere of these structures and create a
precanqerous lesion, then cancer risks of the order
of 10 to 10 per particle can be expected for
burdens much less than 108 particles."
"For occupational exposure the maximum pen.nssible
lung burden (MPLB) of Pu238 or Pu239 is 0.016u Ci,
Assuming a particle diameter of 0.3p, this^burden
is equivalent to 3 x 106 particles of Pu 0? or
104 particles of Pu23802- If there is a possibility
of tumorigenic risks of the order of 1/2000 per
particle, this raises serious doubts as to the
applicability of current MPLB to risk judgments
involving particulates"."
* * *
During the following year the analysis was extended, and discussion
of the conclusions and their potential implications was given considerable
internal distribution within Lawrence Radiation Laboratory1 (Livenrare) and
the Atomic Energy Commission. In November 1969, Arthur tamplin and myself
sent a letter (included as Appendix III) to John ToMer, then Director of
the Division of Biology and Medicine (AEC), with a copy to Glenn Seaborg,
then Chairman of the Atomic Energy Commission. I quote from that letter:
"This problem concerns the biological hazard
attendant upon the inhalation of plutonium oxide
particles. Our analysis of this problem suggests
that these particles may represent a unique
carcinogenic risk—that, when the lung exposure
-------
occurs as a result of PnOp particles, tho existing
maximum permissible lung burden may be too high by
orders of magnitude,. If our suspicions are correct,
the AEC could be confronted with a situation similar
to the uranium miners in the Plutonium industry.
The enclosed report, UCRL-50387, ADDENDUM, is the
basis for the above statements.
Our interest in this problem resulted from being
requested to be members of the DBM Committee of
Space Nuclear Systems Radiological Safety Matters.
As you can see from the enclosed letters to Dr. Bruner,
we disagreed with the Committee's conclusions
beginning in August 1967. The more we studied the
problem the more concerned we became as evidenced
by the letter to Dr. Bruner of October 2, 1968. In
this letter and the memo to Dr. Gofman we1 expressed
our concern with respect to exposure of workmen in
the very vital plutonium industry. We again expressed
this concern at a briefing of the AEC Staff inn
Germantown on October 25, 1968 (copy enclosed).
We are calling this problem to your attention at
this time because it appears that it will soon
become a subject of public debate. As a result of
the fire at Rocky Flats, Dr. E.A. Martell has been
conducting an environmental survey to determine the
levels of Pu-239 in the Colorado area. As we
understand it, he will probably be releasing his
results in December. His results will show evidence
of contamination from the Rocky Flats plant. Our
impression is that he will at that time raise the
question of permissible exposure.
It is important to note that there is no official
guidance concerning exposure to these hot-particles.
ICRP publication #9, page 4, paragraph 20 states,
'In the meantime there is no clear evidence to show
whether, with a given mean absorbed dose, the
biological risk associated with a non-homogeneous,.
distribution is greater or less than t,he risk resulting
from a more diffuse distribution of that dose in the
lung.
Mow, qui C2 obviously, we do not foel thai; the
Division of Biology and Medicine can adequately
support the position taken by the Committee on Space
Radiological Safety. Hopefully, the scientific
commun'ity-at-large will be more receptive to their
arguments but we doubt it."
* * *
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301
In April of 1970 I was invited to the University of Colorado to debate
with Chester Richmond (Los Alamos Scientific Laboratory) on the potential
significance of the offsite contamination discovered around the Dow Chemical
Rocky Flats Facility. I concluded my talk, "Plutonium and Public Health,"
(included in slightly modified form as Appendix IV) with this statement of
perspective:
"Finally I would like to describe the problem in
a larger context. By the year 2000, plutonium-239
has been conjectured to be a major energy source.
Commercial production is projected at 30 tons per
year by,1980, in excess of 100 tons per year by
2000. Plutonium contamination is not an academic
question. Unless fusion reactor feasibility is
demonstrated in the near future, the commitment
will be made to liquid metal fast breeder reactors
fueld by plutonium. Since fusion reactors are
presently speculative, the decision for liquid
metal fast breeders should be anticipated and,
Plutonium should be considered as a major pollutant
of remarkable toxicity and persistence. Considering
the enormous economic inertia involved in the
commitment it is imperative that public health
aspects be carefully and honestly defined prior
to active promotion of the industry. To live
sanely with plutonium one must appreciate the
potential magnitude of the risk, and to be able
to monitor against all significant hazards.
*
"An indeterminate amount of plutonium has gone
offsite at a major facility 10 miles upwind from
a metropolitan area. The loss was unnoticed.
The origin* is somewhat speculative as is the
ultimate deposition.
"The health and safety of public and workers
are protected by a set of standards for plutronium
acknowledged to be meaningless.
"Such things make a travesty of public health,
and raise serious questions about a hurried
acceptance of nuclear energy."
* * *
*
The offsite contamination was, of course, ultimately fixed at
several curies; the source of the contaminationjwas concluded to be leaking
barrels of piutoniurn-contaminated cutting oil which were located in
outside storage.
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302
In a July 8, 1971 letter (included as Appendix V) to Stanley Greenfield,
then Assistant Director of the Environmental Projection Agency, I commented
on the treatment of plutonium hazards in the Atomic Energy Commission's
Draft Environmental Impact Statement on the Proposed Rocky Flats Plant
Plutonium Recovery Facility:
"More specifically, the exposition in paragraph
4 of Section 2.0 is an inadequate and unrepresentative
description of the uncertanties in human risk attendant
to exposure by plutonium aerosols, Human lung tissue
has a well known carcinogenic potential under a number
of situations, including radiation exposure; the
Hanford beagle study demonstrates induction of lung
cancer by plutonium aerosols. These are sufficient
basis to establish plutonium induced lung cancer as
a legitimate concern for humans. Judged in this
context the negative results of the cited mouse study
have little public health relevance. In addition,
it requires pathological optimism to find reassurance
in the results of the Hanford beagle experiment. Dogs
wereqgiven aerosol burdens of M-IO microcuries of
Pu"9C>2. At nine years post exposure the lung cancer
response was virtually saturated and multicentric
origin were noted in some dogs. A correlation observed
between initial.burden and time to cancer death was
used to infer the limit burden for no life shortening
that was mentioned in the draft statement. The
exclusive interpretation of this crude correlation
to mean a practical threshhold of burden is no more
than a promotional indulgence. The observations do
not necessarily imply that a practical threshhold
exists below which no plutonium induced cancer will
occur. Moreover, the range of exposures above the
inferred limit burden may in fact, be interpreted as
a region of saturated response, that is,a burden
regime in which cancer induction in a population,.
approaches 100% during a normal life span. The point
here is that the time to death may be related to the
burden through population depletion, rather than through
1 h:> 'Utb'rih period. In the* foniK-r case, rtpprociabl*3
cancer incidence v;ould be anticipated ctt lower burdens.
To summarize a specific concern with the plutonium
problem: 1) under a number of probably circumstances
plutonium forms aerosols; 2) the physical character of
these aerosols is such that on inhalation by humans they
are preferentially deposited in the deep respiratory tissue;
3) because of slow clearance and because of the insolubility
of the aerosol, particles deposited in this tissue may
experience long residence times (hundreds of days);
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303
4) an appreciable mass fraction of the aerosol is
associated with particles sufficiently large that
significant (> 1 alveolus) volumes of lung tissue
will be exposed to intens'e radiation exposure
(> 1000 rem) within a meaningful physiological time;
5) studies of the effects of intense local radiation
(Albert, Hulse (skin), Maldague (kidney), deposition
hotspots in bone seeking alpha emitters) suggest
that despite the near mitotic sterilization of the
involved tissue an enhanced carcinogenic potential
may exist, in the sense that energy dissipated in a
limited volume may be far more carcinogenic than if
the same radiation were to dissipate its energy over
a larger volume. The question is then do the larger
particulates in a plutonium aerosol lead to associated
alveolar exposures that have enhanced carcinogenic
potential. If they do, then present standards can
be in error by 2-3 orders of magnitude. Notice that
the emphasis here is on the anomalous risk that may
be associated with a single particle; and that if
any threshold is relevant, it is not the dose threshold
since local exposures are large, but rather A structural
or volumetric threshold that must be exceeded by the
physical extent of the exposure; and finally that
this is a very special case of the low exposure
problem, a case that is peculiar to plutonium as
an insoluble aerosol-forming, long lived alpha-emitter.
"In relation to the preceding, the Hanford beagle
study (a-1-10 nricrocuries initial lung burden) showed
cancers appearing in conjunction with radiation induced
lesions. In addition, a dog having substantially less
burden was prematurely sacrificed and no lesions or
cancers were found. It would, however, be precarious
to infer that absence of lesions implies no
carcinogenic potential, or equivalently that radiation
induced lesions are a necessary condition for high
dose carcinogenesis. This point is illustrated by
Albert's rat skin experiment, where carcinogenesis
was optimal in a pre-ulcerative regime of less'drastic ,(
radiation injury. Jl
i
"It would be useful to have a formal documentation of
past plutonium experience for humans, in order to
judge the pxtunt to which that experience can be used
to quantify the hazards of plutonium. In the past 2
years the AEC has established a plutonium registry at
Hanford. If any currently useful documentation is
available from the registry, I am unaware of it.
"Dr. Langham at LASL has for some 25 years followed
12 humans with burdens in excess of a MPL. It is my
impression, perhaps erroneous, that these burdens
largely derive from exposures experienced in a waste
recovery area where the plutonium aerosol was in fact
-------
a dilute solution. If Hiis is the case the relevance
of this documentation to particulate exposure v,'ould
be speculative.
"Independent of the biological questions, there are
substantial and significant uncertainties associated
with the resuspension of plutonium surface contamination.
The subject receives essentially no comment in the
draft statement. In the case of accidental release of
plutonium with consequent contamination of an uncontrolled
area, resuspension phenomena along with carcinogenic
injury will determine the hazardjto inhabitants of the
area. Uncertainties in these two factors will be
important in the public determination of an acceptable
level of surface contamination, especially in the
absence of official guidance for this latter quantity.
The acceptable level of contamination will in turn
determine the costs of cleanup of property and long
term displacement of people."
* * * ' j
Most recently I presented my views in a formal comment on the
discussion of health effects of plutonium in "Particle Lung Dose Effects" of
WASH-1535, Draft Environmental Impact Statement, Liquid Metal Fast Breeder
i
Reactor Program, March 1974. What follows here closely approximates that
comment.
The estimate of lung cancer incidence associated with the inhalation
of plutonium (or other insoluble alpha-emitting transuranics) in particulate
form is a critical factor, along with source terms and resuspension, in
defining the probable impact of a plutonium based fuel-cycle. In the past,
most administrative estimates of lung cancer incidence associated with the
inhalation of plutonium particulates have been based upon a calculation of
the average radiation dose delivered to the lung, and application of tumor
incidence estimates for a uniformly irradiated lung. (See for instance,
"Particle Lung Dose Effects" in WASH-1535, Draft Environmental Impact
Statement, Liquid Metal Fast Breeder Reactor Program, March 1974.) In my
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• 305
Judgment this procedure is not a scientifically defensible basis for public
health evaluations of plutonium hazar.ds.
It is generally acknowledged the 'insoluble' particles of radioisotopes,
when deposited in tissue, provide focal regions of high radiation dose rates.
There is no presumption that the exposure by particulates of plutonium is
uniform. i
The structure and function of lung tissue is such that this tissue is
peculiarly accessible and vulnerable to such particulate exposures. The deep
Q
respiratory tissue of the lung is made up of ^ 10 alveoli. Each aveolus is
a complexly organized unit of tissue. If an insoluble alpha-emitting
i
particulate is deposited in this tissue some 100 or less alveoli will be
exposed during its residence. A crude measure of the nonunifortuity or
inhomogeneity of this exposure is that at most about one-millionth of the
lung's alveoli are affected by a single static particulate.
i
The significance of the preceding is that in the actual lung
exposure by an alpha-emitting particulate, the energy of the ionizing
radiation is deposited in a very limited volume of tissue, and hence that
the scale of the actual radiation dose to lung tissue is roughly a million
times larger than the dose associated with an averaging of the equivalent
radiation energy over the entire lung. t '
A multiplicative difference of a million in a significant physical
quantity generally suggests a qualitative difference consequent to that
quantitative difference. Suppose, for example, that the problem were to
(
estimate the effects of rifle bullets on human organisms. Suppose that the
bullets weighed 1/2 ounce and had a velocity of 1000 ft/sec. Note that the
effect of the projectile depends on the energy,, and note that a 6 ton vehicle
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306
moving at 1 mile per hour has similar energy. There is experience with humans
stopping slow moving vehicles by exerting strenuous counterforces. Using
this experience the effect of rifle bullets on humans is inferred to be
oxidation of the biological fuel necessary to do the work of stopping the
vehicle. But this reasoning is manifest nonsense. Even though the energies
involved are similar, human tissue distinguishes between a fast-moving rifle
' bullet and a truck weighing a million times more and moving at a one-thousandth
the velocity. The former dissipates its energy in the gross disruption of
local tissue, the latter leads to the ordered and non-injurious oxidation of
biological fuel. The end results become very different as the physical
characteristics of the situation change, and a new biological phenomenon
intercedes. Obviously the way to estimate the effects of rifle bullets is
either from past experience that is explicitly applicable, or alternatively,
to calculate the effects considering the physical characteristics of the rifle
bullet and knowledge of the biological and physical characteristics of the
human organism.
This nonsense example has much the same logical structure as the
usual administrative method of estimating the effects of hot particle or ,
other highly inhomogeneous exposures. There, by introducing a fictitiously
large mass of exposed tissue, the calculated dose becomes commensurately
small. In passing from a real situation, in which a static radioactive!:/
hot particle irradiates 10 to 100 alveoli, to the fictional situation in
o
which the ionizing radiation from the hot particle is averaged over 10'
alveoli, the dose scale has fictitiously decreased by roughly a factor of a
(.
million.
One could argue here that energy averaging over statistically exposed
volumes is also a physically meaningless radiological procedure because the
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307
energy of the ionizing radiation is deposited in a narrow columnar region
surrounding the path of the ionizing particle. The point is, however, that
in certain exposure regimes biological effects do correlate with average
ionizing energy to the exposed volume, and the merit of the procedure is
thus established. It is sufficient in these cases to bear in mind that one
is observing the statistical aggregation of discrete events.
Living tissue shows extensive intra-cellular and inter-cellular
organization. Several regimes of biological response v/ould be expected as
physical (spatial, temporal, energetic) characteristics of tissue exposure
are varied. Carcinogenic response to whole organ exposure by non-acute doses
of radiation will fall in one of these regimes, and this will be a regime
in which there is human experience. From the physical characteristics of
Plutonium aerosols, from the lung deposition experience with aerosols, and
from the lung clearance experience with plutonium particulates, it can be
inferred that at least one class of particles exist which s'ubject lung tissue
to an exposure associated with a different carcinogenic response regime.
This is because another biological phenomenon has intervened.
For hot particle exposure that phenomenon is mitotic death of cells,
i.e., loss of the cell's ability to divide. There is an extensive literature
on the subject. Radiologically induced mitotic death is, in fact* the basis
ii
for treating malignant tissue with ionizing radiation, and is the cause of
most acute symptoms consequent to radiation exposure. Even though the
intercession of extensive mitotic death of cells must inevitably place
certain particulate exposures in a different response regime from whole lung,
non-acute exposures, a compelling argument might be made that the carcinogenic
response in the former case is necessarily less than the carcinogenic response
in the latter. This argument would appear to have merit since mitotic death
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308
of cells, as well as reducing the general viability of the tissue, would also
reduce the number of irradiated cells with carcinogenic potential. Usually
implicit in this argument is a conceptualization of radiation cardinogenesis
as originating with a single-cell, direct-injury process.
To confirm this argument, there is a respectable literature in which
carcinogenesis is described as occurring after doses of radiation that are
sufficiently local as to not be organism lethal, and that are sufficiently
high for the fraction of mitotically competent cells to be greatly reduced,
i.e., to 1% or less. Unfortunately, in at least some of these experiments,
the most elegant of which is Albert's experiment on rat's skin, carcinogenesis
is contrarily related to the fraction of mitotical'ly competent cells, i.e.,
cancer induction in the regime where mitotic competence is greater than 1%
is small compared with the cancer induction in the regime where mitotic
competence is much less than 1%.
There are several points to be made here. Loss of mitotic competence
and carcinbgenesis are two indices of radiation effect in tissue. They
cannot be independent since cancer cells are mitotically competent, hence
the relationship between these indices can tell us something about modes'of
radiation carcinogenesis.
Mitotic competence, i.e., the fraction of mitotically competent cells,
is not generally related in a linear way to carcinogenic response. Moreover,
11 \^ ei major dnom-ily t!;,i!', an incrr>orvocl in
dose regimes associated with greatly reduced mitotic competence. It is
difficult to reconcile this result with any single-cell, direct-effect origin
for radiation induced cancer in high dose regimes. (On this point see the
results and discussion in "Tumor Induction in Rat Skin by 300-kv X-rays and
15 MeV Neutrons" in IAEA-SM-118/22, G.W. Barendson.)
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309
Mitotic competence of a cell population decreases exponentially with
increasing alpha-radiation dose and'.is a fairly general index of radiation
effect in tissue. If radiation carcinogenesis universally decreased with
mitotic competence, then estimates of carcinogenesis based on a fictitious
averaging of a local inhomogeneous dose over a much larger volume would be
necessarily conservative. Since radiation carcin,ogenesis can, and in fact,
does increase to anomalously large values while the mitotic competence
becomes vanishingly small, the fictitious averaging of dose over larger
volumes is not necessarily conservative. Instead it would appear that
situations exist in which an intense local dose of ionizing radiation can be
a far more efficient carcinogen than a diffuse tissue exposure with the same
type of ionizing radiation and the same total energy. The above then implies
that averaging of dose over fictitiously large volumes may be far from
conservative, especially if the averaging obscures much diversity and detail
of the actual exposure.
It is obvious that as a local exposure becomes more intense, a stage
must finally be reached where the carcinogenic efficiency of the exposure
(on a per unit energy basis) is reduced. This is not pertinent to previous
arguments. It suggests caution, moreover, in generalizing relative
carcinogenic efficiencies from the comparative results of high dose
,1
inhomogeneous and homogeneous exposures. This caubion applies to the
discussion oF the rat skin experiments of Passonneau of., nl. and the hamster
respiratory tissue experiments of Little et. al., in "A Radiobiological
Assessment of the Spati?! uistr !..*„.on of ,\uuiation Dose from Inhaled Plutonium"
(WASH-1320/5 ii. ouif, •„. .vichiiiUi.j ant, u. i.^^nuiii.
What one wishes to know is the characteristics of the most
carcinogenically efficient exposures and the amplitude of that carcinogenic
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-VI-
response. In the absence of an understanding of the mechanisms of carcinogenesi
this is the knowledge most useful in defining the conservative limits of theoret
risk associated with the diverse and complex tissue exposures by plutonium
particulates. Albert's experiments were unique in providing that kind of
refined description. For example, cancer induction was observed to be large
only in a close region where virtually all ce,lls were mitotically sterilized,
i.e., where only "\% to .0001% of the cells would be expected to have the
ability to divide. Cancer induction was maximum for pre-ulcerative exposures,
i.e., exposures where no gross lesions (total tissue disruption) were
produced. Cancer induction was nearly proportional to the production rate
of atrophied (disordered) hair follicles, and correlated with the dose to
the minimally exposed germinal cell population of the hair follicle. Most
importantly, with carefully chosen exposures, cancer production rates could
5
be made as anomalously high as ^ 1 cancer per 10 ergs which differs by orders
of magnitude from cancer induction rates per unit energy associated with
indiscriminant exposures. The observation of such a carcinogenic resonance
(anomalously large response) for a specific tissue and a specific exposure
regime is significant because it demonstrates the existence of such
energetically efficient exposure situations. The amplitude of this response
can then provide a reasonably conservative estimate 'of risk for the diverse
and complex exposure of another tissue.
The Albert experiment illuminates the difficulties associated with
describing radiation carcinogenesis and predicting the response, in the absence
of an understanding of the underlying mechanisms. Even though a relatively
simple tissue was involved, if the experiment had not been so carefully
structured, much of the detail would probably have been lost, and with it the
knowledge of this resonance in radiation induced skin cancer in rats. Detailed
predictions in the anomalous regime would then have been erroneous.
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1 311
239
Returning to the question of plutonium risks, a picocurie of Pu
emits ^ 10 ergs of ionizing radiation per year; a maximum permissible lung
burden (occupational) emits ^ 10 ergs of ionizing .radiation per year. -
Considering the wide variations in tissue irradiation following exposure to
a plutonium aerosol, and considering the energy of the associated radiation
exposure, when compared with the energy required per cancer in Albert's
experiment, one is compelled to a concern that the wide diversity in plutonium
particulate exposures will discover similar resonant responses, and that the
amplitude of these responses and their extent in the total'domain of
exposures will be sufficient to dominate the overall carcinogenic risk. This
concern is further exacerbated by inclusion of a compensating RBE factor of
^ 10.
A comment should be introduced here on the concept of "waste radiation."
Depending upon one's assumptions about the mechanisms of radiation carcinogenesis
certain radiation induced biologigal effects may be considered unnecessary or
undesirable for cancer induction and hence the radiation expended in
producing those effects is wasted or without carcinogenic potential. Examples
are cell sterilization, if one assumes that dead cells can not contribute to
t
carcinogenic potential; or multiple sterilization of the same cell, if one
assumes that while a sterile cell may increase carcinogenic potential,
' j'1
duplicate sterilization leads to no further increase. The most frequent
example is the radiation wasted in exposures subsequent to induction of an
autonomous cancerous legion ivy a chronic exposure. This list is obviously not
intended to be exhaustive. The point is that the hypothesis underlying the
use of the concept should be differentiated to distinguish its meaning in a
particular case. By invoking the notion of "wasted radiation," and by
hypothesizing and proving certain exposure situations to be without carcinogenic
potential, one could, in principle, quantitatively modify the previous concern,
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312
by, for instance, showing that virtually all of the energy was without
carcinogenic potential. Given'the state of uncertainty surrounding both
tissue function and radiation carcinogenesis, it seems doubtful that such
an approach can make a significant contribution to hazard evaluation. More
sensibly, if one knew the risk one could probably infer something about the
appropriate conceptualization of wasted radiation and carcinogenesis.
The following excerpt taken from "The Effects on Populations of
Exposure to Low Levels of Ionizing Radiation," Report of the Advisory Committee
on the Biological Effects of Ionizing Radiation, NAS/NRC, summarizes the state
of knowledge concerning the causation of cancer (emphasis added):
i
"Although the mechanisms of carcinogenesis, or of
radiation carcinogenesis in particular,- are not fully
known, available information implies that most, if not
all, types of cancer develop as a result of the combined
effects of multiple factors. These causative factors
may include: prezygotic (inherited) mutations of
chromosomal aberrations, which can spread during
development to many kinds of cells; somatic cell mutations
or chromosomal abberations, which can be acquired at
• any time after conception; changes resulting from the
action of viruses; and changes in systemic growth factors
(e.g., depressed immune competence, hormonal imbalance)
and in local tissue regulation (disorganization, damage),
such as may result from diseases other than cancer or
from advancing age.
"Although point mutations, chromosomal( abberations,
and other changes at the cellular and molecular'.level
may require only small doses, tissue disorganization and
gross disturbances in physiology are unlikely without
larger doses.
"OF l.h-! iii-iny types of chrm<|p'; wlrich r<'id i.'i tinn c'm
cause in cells or tissues, none is considered Lo be
unique for radiation. Many, if not all, such changes
can presumably result from a variety of other agents."
This summary view on carcinogenesis does not conflict with the ideas leading
to the conclusion reached earlier, that fictitious dose averaging to larger
tissue masses need not be conservative. The possibility of various modes
-------
-17-1
313
of carcinogenesis, including tissue disruption, is acknowledged. In particular,
the number of causative factors proposed is a measure of the considerable
range of hypotheses available to describe experience.
Disease profiles are highly species specific. Cancer is no exception.
Gross characteristics are obviously highly species specific also. A rat and
a moi|se are distinct and yet morphologically are very similar. The gross
tissue differences are articulated out through subtly different informational
coherences amongst cell populations, - the collective behaviour being phased
ultimately, by a biochemical dialogue between cell neighborhoods whose
functional potential is genetically moderated. Not to belabor this point
i
unnecessarily, - cancer profiles are species specific; gross characteristics
and, of course, genetic material are also species specific. In high dose
carcinogenesis collective detuning of tissue by tissue disruption seems as
acceptable an origin for the tissue instabilities of cancer as does an
isolated single cell event involving the cell's genetic material. This is
not to say that tissue disruption is a necessary condition for carcinogenesis,
or even a sufficient one without some specific qualifications.
* * *
Return now to the problem of risk estimates associated with.radioactive
i
particulates in human lungs. Most of what has been said earlier in this comment
has been general, and has baen aimed at showing that there was no inherent
conservatism in the tissue averaging method of estimating cancer risks, and
that moreover the method could be far from conservative. The conclusion
could as well be applied to lymphatic tissue or to bronchial tissue.
Having this background, notice that human lung tissue has a well known
carcinogenic potential under a number of situations, including exposure to
-------
314
ionizing radiations; and that in the Hanford dog study induction of lung
cancer was observed after exposure to plutonium aerosols. These are a
sufficient basis to establish plutonium induced lung cancer as a legitimate
concern for humans.
The following is a review of the official guidance for estimating
the carcinogenic effects from exposure to radioactive particulates:
"(210) The NCRP has arbitrarily used 10% of the
volume of the organ as the significant volume for
irradiation of the gonads. There are some cases in
which choice of a significant volume or area is
virtually meaningless. For example, if a single
particle of radioactive material fixed in either
lung or lymph node may be carcinogenic, the averaging
of dose either over the lung, or one cubic centimeter
may have little to do with the case. Use of
significant volumes or areas must be looked on as
one of the round off devices which in special cases
must give way to detailed study."
NCRP Report #39
Basic Radiation Protection Criteria
January 15, 1§71.
"(20) In the case of non-homogeneous distribution
of absorbed dose in the lung, an estimate of the Dose
Equivalent to the whole lung, determined merely by the
product of 0 F and the mean absorbed dose, may be
greatly in error, but our full undersLanding of this
problem must await further experimental evidence.
In the meantime there is no clear evidence to show
whether, with a given mean absorbed dose, the biplogical
risk associated with a non-homogeneous distribution is
greater or less than the risk resulting from a more
diffuse distribution of that dose in the lung."
ICRP F'libl ication 9
Recommendations of the
International Committee
on Radiological Protection
(adopted September 17, 1965).
-------
-19-4
315
"41. On the basis of general considerations and
of some experimental data, and clinical experience the
Task Group were of the opinion that, for late effects,
the same radiation energy absorption might v;ell be less
effective v;hen distributed as a series of "hot spots"
than when uniformly distributed. Thus, with particulate
radioactive sources within a tissue, a mean tissue dose
would probably introduce a factor of safety."
ICRP Publication 14
Radiation Sbnsitivity and
Spatial Distribution of Dose
(Publication 14 appears as a
report of two Task Groups,
and not as the official
recommendations of the ICRP.)
The recommendations of the National Council on Radiation Protection and
Measurement set forth in Report #39, and the recommendations of the
International Commission on Radiological Protection set forth in ICRP
Publication #9, are specific in offering no explicit guidance. Any implicit
guidance intended in these recommendations would seem to bear most directly
on the validity of existing standards when applied to highl^ inhomogeneous
exposures.
The third citation taken from ICRP Publication #14 is a report of
an ICRP Task Group and is not intended to provide dispositive official
guidance. The discussion there is useful commentary, but is conditional and
inconclusive without some quantitative definition. Certainly alpha-emitting
participates as they pass to sufficiently high activities must become
energetically inefficient carcinogens. Th-vt, however, is not in itself an
interesting issue.
With regard to the previously cited method of risk estimation based
on dose averaging, supporting reference is often made to the Hanford beagle
experience. The following statement taken from WASH-1585 is typical of
such arguments:
-------
316
"The average dose approach leads to estimates comparable
to those of Gavankar following Thompson ej^ aj_ based on
linear non-threshold extrapolation of observations on
beagle dogs administered PuOg aerosols."
The observations on beagle dogs deserves separate consideration.
It requires unnatural optimism to extract reassurance from the results
of the now completed Hanford beagle experiment. Dogs were given initial
239
Pu 0- burdens in the microcurie range. By nine years post-exposure the
lung cancer response was virtually saturated and multicentric origins were
noted in some dogs. Those receiving larger lung burdens greater than 10
microcuries died of pulmonary insufficiency within 4-1/2 years. Twenty-one
dogs survived for more than 4-1/2 years, and only one of these did not
exhibit lung cancer at death. A relationship observed between initial lung
burden and time to death with cancer has been often used to infer a threshold
burden below which no life shortening of dogs would be expected. These
results are usually exhibited on a log-log graph which obscures virtually all
differential detail. Most importantly,recognize the nature of the experiment,
i.e., the lung burdens v/ere large, the results were saturated, and the number
of animals was small. The crude relationship observed between initial lung
burden and time of death with lung cancer does not necessarily imply that a
threshold burden exists for beagles. Quite to the contraryii'the range of
exposures above the inferred threshold burden may be interpreted as a region
of saturated carcinogenic response, that is a burden reqima in which lung
cancer induction in a beagle population approaches 100% during a normal life
span. The point is that the observed time to death is more likely related
to the burden, through a population depletion effect, rather than through
a burden dependent latent period. In the former interpretation appreciable
cancer would be anticipated at lower burdens. This is again consistent with
the extensive observations in "Toxicity of Radium-226 in Mice" (IAEA-Sf'I-118/11)
-------
-21-
31?
M. Finkel, et. al., of radioisotope-induced bone tumors in mice, v/hich support
their interpretation that "latent period is constant and that the apparent
relationship between increasing dose and decreasing time to death with tumor
is due to the effects of dose-level on survival and on tumor expectancy."
The significance of the Bair beagle experiment is that it demonstrates
carcinogenic potential in bronchiolar-alveolar tissue of beagle dogs after
their having been exposed to microcurie quantities of plutonium. Cancers
were observed in conjunction with fibrotic lesion.
* * *
i
The domain of this comment is broadened here in order to summarize a
specific concern with plutonium, and certain other active alpha-emitters,
such as U-233. Under a number of circumstances plutonium forms aerosols.
The physical character of these aerosols is such that on inhalation by humans
they are preferentially deposited in deep respiratory tissue. Because of
slow clearance and because of their insoluble character, particles may
experience long residence times in tissue. An appreciable mass fraction of
the aerosol is usually associated with particles sufficiently large that
small but physiologically significant volumes of tissue will be exposed to
intense (i.e., doses that if given whole body would be organism le.thal)
radiation doses within a meaningful physiological time. Studies of the effects
of intense local radiation to skin indicate that despite the near mitotic
sterilization of the involved tissue, an enhanced carcinogenic response may
occur, in the sense that energy dissipated in a limited volume may be far
more carcinogenic than if the same type of radiation were to dissipate its
energy over a much larger tissue mass. The question is then: do particulates
of certain classes of plutonium lead to exposures that have enhanced
carcinogenic potential? If they do, then present standards can be in error
-------
318
by orders of magnitude.
Notice that the emphasis here is on the anomalous hazard associated
with a single particle; and that if any threshold is relevant, it is not a
dose threshold since local exposures are large, but rather a possible
!
volumetric threshold that must be exceeded by the physical extent of the
exposure. Plutonium, as an insoluble aerosol -forming, 'long-lived alpha-emitter,
constitutes a. very special case of the low exposure problem.
A plutonium industry has existed for more than two decades. By this
time there must be a significant history of human exposure. Considering
the early recognition of pi u'-toni urn's toxicity, and its obvious potential
for much expanded commercial use, the occupationally exposed population must
or should have been closely followed. A plutonium registry has existed
since 1968. An acceptable way to make limiting estimates of cancer risks,
would be to argue conservatively from past human experience. Considering
the extent of past experience, the open literature contains relatively little
detailed information on the history of humans following plutonium exposure.
While I am no epidemiologist, it is clear that the existing literature is an
iikidd'iudfce base tor rigorous argument in support u!r existing standards.
Statements affirming that there have been no recorded cases of human cancer
as a result of plutoniuni exposure must obviously be qualified by supporting
epidemiological analysis of human experience. In the limit, not to have
seen an effect would be a logically sterile observation, if one had not looked.
-------
319
In the absence of such necessary argument, one is left with an
obligation, through public health traditions, to more conservative and
defensible methods of evaluating the cancer risks of alpha-emitting particulates\
For this reason I commend to your attention, "Petition to Amend Radiation
Protection Standards as They Apply to Hot Particl'es." in the Matter of
i
RADIATION PROTECTION STANDARDS AS THEY APPLY TO HOT PARTICLES brought before
the Environmental Protection Agency and the Atomic Energy Commission by.the
Natural Resources Defense Council, Inc., on February 14, 1974, and the supporting
report of Arthur Tamp!in and Thomas Cochran.
I
The hypothesis developed there is scientifically respectable and
represents a state-of-the-art, conservative basis for public health judgments.
I believe that a responsible joining of the public health and scientific
issues would be accomplished by having any reduction in the conservative
i
guidelines proposed there be argued from compelling refutation of the hypothesis,
or from epidemiological studies of human experience.
WASH-1320, "A Radiological Assessment of the Spatial Distribution of
i
Radiation Dose from Inhaled Plutonium, September 1974," I take to include a
reasonable review of the scientific experience bearing on, those two points.
" *,''
I do not find the material presented there a compelling,refutation to the
hot particle hypothesis, as a possible mode of carcinogcnesis. By myopic
and exclusive attention to the disjoint scientific experience that ir, available,
WASH-1320 has obscured the sea of uncertainties in which these fragments of
information are immersed. Moreover, I was disheartened that its discussion
of human experience gave no new definition to that evidently limited body of
knowledge. The aerosol characteristics associated with the early Los Alamos
exposures were conjectured there, without any general discussion of possible
-------
320
aerosol characteristics. Consequently, the relationship of the subsequent
i
analysis to the validity of the hot particle hypothesis becomes similarly
speculative, particularly when one remembers that many of the subjects were
believed to have had a recovery area exposure to some form of plutonium solute.
To my mind the most significant observations in WASH-1320 were those
I
associated with the recently completed Los Alamos experiment on Syrian
hamsters. It appears anomalous that virtually no lesions of any sort were
observed in conjunction with the plutonium microspheres. Certainly the cells
contiguous to these particles were sufficiently irradiated to be mitotically
sterile, and their apparent continued function and(Structural integrity for
the lifetime of the animal raises the question of what are the appropriate
time scales for the cells in lung tissue, and the question of how such
necessarily sterile tissue would react to an overt stress such as a virus
infection. In point, the Lo§ Alamos hamster experiment confirms the opinion
that the response of lung tissue to particulate radiation is poorly understood,
especially when considered in conjunction with Little's experiments with
210
Po showing a high incidence of bronchiolar-alveolar cancer in the same
i
species. It is my recollection that the cancers of this type observed by
Little and by Bair (beagles) were generally located in the peripheral region
•" ,i''
of the lung. Not knowing the distribution of the Los Alamos microspheres
throughout the capillary matrix of the lung, I can not say whether these
observations are oT any pnsr.iulo fssistanco in roconcilinn tha experiments.
Another concern is that the imaginative technique of exposure used in the
Los Alamos experiment may, in fact, have produced a particulate exposure
that was too Static. (Note: see amendment to this paragraph in attachment
following questions.)
Finally, I would like to commend to^your attention Dr. Marten's
research on the potential health effects of ambient alpha-emitters (see his
-------
321
testimony before this Panel). It would be presumptuous of me to comment on
that work more than to say his hypothesis concerns a different particle size,
different target tissues, different mechanisms of qarcinogenesis, and hence
it is disjoint from the hot particle hypothesis even though its implications
to plutonium guidelines may not differ substantially.
* * * i
t
The preceding discussion has no pretensions of being a comprehensive
discussion of the health hazards associated with plutonium. What it does
purport to do, is examine some of the significant uncertainties that bear on
evaluation of those hazards, and to suggest a framework ,in which such
considerations can be conservatively incorporated into public health
considerations.
Despite much scientific effort the mechanisms underlying carcinogenesis
are not understood, and radiationjinduced carcinogenesis isi no exception.
Radiation exposure from plutonium particulates is highly inhomogeneous and
diverse. The carcinogenic potential from such exposures is poorly known for
humans. (
Present standards for plutonium exposure are based on the assumption
of a uniform exposure by this material. For exposure by particulars such
an assumption is manifestly erroneous; and as a basis for making public
h°alth decisions regarding the hazards associated with particulats exposures,
the assumption may be far from conservative. Human experience with plutonium
appears to be insufficiently documented to provide conclusive epidemiological
support for existing standards.
Plutonium is being considered as a major energy source for the near
future. If it becomes a common element in commerce, the guidelines specifying
-------
322 ' •
its control acquire profound public health significance. Beneath the
determination on those standards is the judgment of how scientific
uncertainties relate to public health decisions. Considering the gravity
and irreversibility of this decision I would suggest that a legitimate basis
for establishing standards would be the most conservative hypothesis
consistent with scientific experience. For{ this basis the hot particle
i
hypothesis or the Kartell hypothesis commend themselves for careful ,
consideration.
* * *
Donald P. Geesaman
Associate Professor
School of Public Affairs
University of Minnesota
Minneapolis, Minnesota
-------
323
APPENDICES
I. An Analysis of the Carcinogenic Risk From An Insoluble
Alpha-Emitting Aerosol Deposited in Deep Respiratory Tissue
II. An Analysis of the Carcinogenic Risk From An Insoluble
Alpha-Emitting Aerosol Deposited in Deep Respiratory Tissue
Addendum
[II. Letter - A. Tamplin/D. Geesaman to J* Totter
IV. Plutonium and Public Health
V. Letter - D. Geesaman to S. Greenfield
-------
-------
APPENDIX 1 325
TID-4500, UC-48
Biology and Medicine
e> Xla.clia.-tl.oxx I^E
UNIVERSITY OF CALIFORNIA
UVERMORE
Bio-Medical Division
UCRL-50387
AN ANALYSIS OF THE CARCINOGENIC
FROM AN INSOLUBLE ALPHA-EMITTING AEROSOL
-DEPOSITED IN DEEP RESPIRATORY TISSUE
Donald P. Geesaman
February 9, 1968
-------
326
Contents
ABSTRACT . 1
INTRODUCTION 1
PULMONARY DEPOSITION . 2
PULMONARY CLEARANCE 4
DEEP RESPIRATORY ZONE GEOMETRY 5
TISSUE EXPOSURE 7
SUBMICROSCOPIC STRUCTURE . r 9
RADIATION RESPONSE OF TISSUE 10
IMPLICATIONS 13
REFERENCES • 14
APPENDIX I 15
APPENDIX II 16
-in-
-------
AN ANALYSIS OF THE CARCINOGENIC RISK
FROM AN INSOLUBLE ALPHA-EMITTING AEROSOL
DEPOSITED IN DEEP RESPIRATORY TISSUE
Abstract
327
This paper is concerned with evaluating
the carcinogenic risk from an insoluble
alpha-emitting aerosol deposited in deep
respiratory tissue Pulmonary deposition
and clearance are described; and relevant
times, lengths and geometries are noted
in order to construct a simple model of
00 Q
deep respiratory tissue. Pu O^ and
n o Q
Pu Og are taken as representative aero-
sols in making quantitative estimates of
tissue exposure and response. While no
realistic evaluation of the total carcino-
genic risk is accomplished, the results'
are such as to clarify the nature of the
problem. In particular, if the loss of mi'-
totic competence by a local cell population
is sufficient to guarantee no origin of can-
cer within that population, then the carci-
nogenic risk from particulate sources does
not scale to the total energy dissipated.
To say what dose Characteristics are sig-
nificant to the risk would require an accu-
rate knowledge of clearance, local shielding
responses, and the mechanisms of cancer
induction. In the absence of this detailed
knowledge the suggested course is an
experimental determination of the number
of source particles per induced cancer.
Introduction
The possibility exists that significant
quantities of insoluble radioactive aerosols
will be accidently released into the atmo-
sphere. Inhalation of these aerosols by
a population will involve some carcino-
genic risk. This work arose out of an
ulli'iiupl to understand and rv.'hril'' lli.il
risk.
A general appraisal of the problem is
/
closely related to s€>veral mechanisms
and phenomena. In order lo achieve n
desirable level of completeness, gross
and microscopic structure and function
of the lung are briefly described relative
to the questions of pulmonary deposition
and clearance."'" Relevant characteristic
times and lengths are noted aii(j used in
constructing a simple model of lung struc
turc and function in the deep respiratory
zone. The alpha-emitters, Pu^SSQ,, and
') ij} <)
Pu"' ' O,,' ;!>'(• t.'l.'cn a;-,- rcprosfnlaUvc :ierc
sols''"'" in making quantitative estimates of
tissue exposure and response. While no
realistic evaluation of the total carcinogenic
The material for this description is
principally derived from Ref. 1 and 2.
*#
References 3 and 4 deal specifically
with the clearance of PuO2 aerosols.
-1-
-------
328
risk iS-accomplished, some results are
obtained which clarify the nature of the
problem and suggest the specific areas
of interest in future study.
Pulmonary Deposition
Knowing the characteristics of an aerosol, human respiratory tree along with the asso-
i.e., the size, geometry, density and concen- ciated lengths, diameters, velocities and
tration, it is then possible to make a reliable branching numbers. For a given aerosol
estimate of the deposition in the respiratory the principal mechanism of deposition will
airways. Figure 1 shows in schematic a vary among different regions of the lung.
Branching
number
Length
(cm)
Diameter
(cm)
Velocity
(cm/sec)
n
1.6
6.5
1.5
0.9
16
0.3
0.06
17
19
20
23
0.15
0.08
0.05
0.04
24
0.03
0.03
150
190
200
1.4
Fig. 1. The respiratory tree, schematic drawing and approximate descriptive values
(compiled from Refs. 1 and 2).
-2-
-------
In the upper respiratory tract, i. e. ,
nose-pharnyx-trachea, inertial deposition
is dominant. It occurs when an airway
branches or changes direction, and the
flowing air is unable to act on the particle
with sufficient force to cause it to follow
the flow pattern; consequently the particle
persists in the original direction of motion
until it strikes the wall of the airway and
adheres. This mechanism is especially
effective when aerosols are dense, flow
speeds are large, and airways are tortuous.
These conditions exist in the nasal cham-
bers where the removal of large particles
is accomplished.
In the lower respiratory airways grav-
itational settling accounts for most of the
deposition. It is important when the res-
idence time in an air duct is such that
the distance a particle falls in that time is
of the order of, or greater than, the
vertical size of the duct. Because the total
duct cross-section increases enormously
in the deeper respiratory airways, the'
flow velocity becomes commensurately
smaller, hence residence times are long
and the deposition condition is satisfied in
the deep respiratory zone (DRZ) for
micron-sized particles. It is worth noting
that when the tidal air finally reaches the
alveoli its velocity is almost zero and it
moves nonturbulently into the expanding
alveolar space, simply following behind
the stagnant air.
For submicronic particles, deposition
by Browruan diffusion is significant. Since
the diffusion amplitudes for the residence
times involved are generally small corn-
fared to the duct dimensions of the ves-
tibular airways, the mechanism is only
important for submicronic particles enter-
ing the stagnant alveolar air spaces'where
residence limes are large.
It is easy to identify these effects in Fig. 2,
which shows the percentage deposition of a
plutonium oxide aerosol as a function of
size. Note) the maximum around 0.75 u in
the deep respiratory zone branch. While
the general structure of the deposition
curves is typical, there will be some curve
displacement and variation in shape for
aerosols of different density and geometry.
329
0.1
Fig. 2.
Particle size in microns
Pulmonary deposition curves for
a PuO2 aerosol, (reproduced
from HEALTH PHYSICS IJ3; 881,
1967 by permission of the
Health Physics Society, after
Fig. 6 of Mann and Kirchner (5).
Figure 2 should have been replaced by its'improved counterpart in the
Report of the ICRP Task Group on Lung Dynamics in Health Physics. 12:173 (1966).
-3-
-------
330
Pulmonarv Clearance
Once a particle is deposited in the
respiratory tract its fate depends princi-
pally on its locality. Airways from the
terminal bronchioles upwards are ciliated,
and a mucous coat is propelled up the
tract with a velocity of the order of 1
cm/min, though the velocity in the smaller
bronchi is somewhat reduced from this
vsilue. Particles residing on this mucous
coat are usually removed to the mouth in
a matter of an hour.
In the deep respiratory zone the ducts
are not ciliated; there is, however, a
thin mucoid coat on all air tissue surfaces
and macrophages adhere to the alveolar
walls. It is thought that particles deposited
in this region are ingested by macrophages
and that most of these cells then detach
from the alveolar wall and are removed in
some poorly understood way to the mucous
blanket of the terminal bronchiole. This
transfer is not believed to be accomplished
by actively directed rnacrophage motion,
as no tropism has been demonstrated.
Possibly the mucous movement in the
terminal bronchiole induces, through
viscosity, a slow flow in the mucous coat
of the deep respiratory zone in much the
way that a river would disturb a backwater.
It is more likely, however, that the motion
of the mucous-covered alveolar walls
during breathing is such that it acts to
pump surface debris out of the alveoli.
Whatever the mechanism, there is ob-
served a fairly rapid phase of clearance
from the region. The half-life for this
process is of the order of a few days,
though this depends on the magnitude of
the lung burden. For small burdens the
rate of clearance seems to increase with
the burden, at larger burdens the response
is saturated and the clearance mechanism
is less effective.
A much slower clearance is also ob-
served from this region; it has a time ,
3
scale of 100's of days. Again the process
is not well understood; it is assumed that
some pprticles are rendered static in the
deep respiratory zone of the lung, and a
few of these are occasionally mobilized,
at which time they may be susceptible to
the usual clearance path. The mechanism
of immobilization is conjectured to be
macrophages that, for some unknown rea-
son, do not detach after ingestion, and
I
instead remain at the site, proliferating
and developing a supporting structure of
connective tissues. These anomalies,
called plaques, tend to appear in regions
that because of structure or injury are
more rigid, for example, where an alveolus
opens into a respiratory bronchiole. The
plaques are rigid structures and hence tend
to immobilize the surface still more, which
is likely to further reduce the effectiveness
of the clearance mechanism for that vicinity.
The association of plaques with static
regions in the alveolar wall tends to bear
out the idea tha^the normal clearance of
the deep respiratory ione.'.is supported by
the excursion^ of the alveolar wall. It
does not, however, rule out the induced-
How explanation of clearance1, and in fact
the two mechanisms may complement each
other. The later release of particles is
taken to occur when rnacrophage death
within the plaque allows the release of a
fraction of the ingested particles.
Some particles find their way into the
pulmonary lymph nodes. Though a few
-4-
-------
331
may actually penetrate directly into the
interstitium in regions where the capillary
network is relatively diffuse, most of the,
lymph burden derives from the plaques
which cause the adjacent alveolar walls
to lose their capillaries and basement
membranes, thus making it possible for
a ruptured cell in the plaque to empty
some of its contents directly into the inter-
stitial space from where it finds its way
to the lymph node. The time scale for
this clearance is observed to be the
same as slow pulmonary clearance to the
outside, which is consistent with the ex-
planation.
With this description of clearance,
characteristic scales can be assigned to
particles experiencing the various phases
of clearance. These are given in Table I.
Because of their potentially long residence
times, radioactive particles in the deep
respiratory zone constitute an unusual
risk. This is the particular problem that
I want to describe.
Table I. Characteristic scales of pulmonary clearance.
Upper respiratory clearance
Fast DRZ clearance
(moderate burden)
Slow DRZ clearance
Length
~25 cm
~ 2 mm
0
Time
~l/2 hr .
~ 2 days
~500 days
Velocity
~1 cm/min
~1 mm/day
0
Deep Respiratory Zone Geometry
To obtain some notion of the bulk nature
of a lung, refer to ^Table II showing the
fractional composition by volume of typi-
cal human lung at three-fourths maximal
inflation. Renormalized values compati-
ble with half-maximal inflation are includ-
ed in the table. Notice that the lung is
about 80% air and that most of this is in
the alveoli and their vestibular air spaces.
This should give some appreciation of
the porous and sponge;-like character of
an inflated lung. Ninety percent of the
gross volume is made up of sac-like
o
alveoli, about 10 in total, clustered
about airways which have undergone from
one to seven branchings between the
terminal bronchiole and the alveoli.
Many different clusterings occur, but all
achieve the same effect; that is, close
packed alveoli sharing the same thin walls,
and ventilated by a set of vestibular air-
ways with approximately one-half the
alveolar volume. An alveolus is best re-
presented geometrically as a truncated
sphere; collectively they can be pictured
as a honeycomb-like structure wrapped
around a duct. The ducts are generally so
," «'!
branched or alveolated as to have no
,1
internal surface.
Table III gives some idea of the di-
mensiona involved with I he DK/i geometry.
These will vary somewhat in other species
because the alveolus size is an inverse
function of the organism metabolic rate.
For my purposes it was sufficient to re-
gard the deep lung tissue as a cubical
lattice characterized by the length of a
side, d,-and a wall thickness, r. These
-5-
-------
332
Table II
Fractional compo;;'lion of a hitman lung at three-
auarters and one-half maximum inflation.
*
Three-quarters maximum inflation
Connective and conductive 'structures
DRZ
Air in alveolar ducts and
respiratory bronchioles
Air in alveoli
Blood barrier
"Epithelial 0.009
Interstitial 0.012
Endothelial O.Oob
Capillaries
Pre- and post-capillary
0.1
0.29
0.54
0.03
0.03
0.01
0.90
One-half maximum inflation'1"1"
Connective and conductive structures
DRZ
Air in alveolar ducts and
respiratory bronchioles
Air in alveoli
Blood barrier
Epithelial 0.012
Interstitial 0.016
Endothelial 0.012
Capillaries
Pre- and post-capillary
0.14
; 0.27
0.49
0.04
0.042
i 0.014
0.86
portion of the table is taken from Ref. 2.
sj<
Renormalization of the data for three-quarters maximum inflation.
Table III. Characteristic sizes (in microns)
in the DRZ.
Alveoli
Alveolar duct
Respiratory bronchiole
Alvpolai" septum
200 - 300
200
500 X 1500
3-10
values can be chosen in a way that is
compatible with DRZ densities, since this
is the crucial parameter for determining
the range of ionizing radiation. When
this is done for the average lung data
(see Appendix I) the results are d - 200 u,
r= 8 M at one-half maximum inflation; and
d = 230 n, r - 6 M at three-fourths maxi-
mum inflation. «'
In the lattic'e model the wall is treated
as being elastic and uniform in thickness;
in tnol it is corr u;;,itf:d on length scales of
a few microns. This structure primarily
derives from distensions associated with
the capillary mesh in the walls. The
length scales of the radiation problem are
sufficiently large that the approximation
of uniform walls should have no appreciable
consequences.
-6-
-------
Tissue Exposure
333
To see what kinds of volumes are ex-
posed by a radioactive source consider a
r\ n p
l-(j, particle of Pu (X embedded in the
lattice. From P'ig. 2 this size is nearly
optimal for deposition in the deep respira-
tory zone. Pu2 emits 5.5-MeV alpha
particles and has a half-life of 89 years.
A particle of this size is a 60-pCi source
and has a total alpha flux of about 200,000
per day or 2.2 per sec. The range in
tissue, R, of 5.5-MeV alpha is 41.5 u;
there is no appreciable attenuation because
of the size of the particle.
Since the range in tissue is greater than
a septal thickness, the geometric range of
an alpha as a function of field angle works
out quite simply to be as shown in Table
IV. The reasons for this result are clear.
Table IV. Angular dependence of the geo-
metrical range of an alpha source
in a cubical lattice geometry
(For a derivation see Appendix II.)
1) Along lattice axes D ^ ~
(defined by source)
D -J
2) In lattice plane D
(defined by source)
3) In other directions D
where r = septal thickness
R ' range in tissue
d = cube dimension
D = geometric range
and it is assumed that
R> r .
The geometric range D must scale like
Rd/r, and a factor of 1, 2, or 3 must
occur in the denominator depending on
whether the field direction intersects with
1, 2, or 3 sets of the orthogonal planes
which generate the lattice.
Hence the exposed volume can be thought
of as a sphere of radius ftd/3r, on which
are superimposed discs of radius Rd/2&
and thickness d lying in the three 2-axis
planes, on which in turn are superimposed
n
arms of length Rd/r and cross-section d
in the six axis directions. The volume
exposed is [just
47T
R \3 , 57/R\2 , ,/R
) +r2 7) +3 7
where the bracketed expression is the num-
ber of alveoli in the volume, and the 3
terms are the sphere, disc and arm terms
respectively. For the lattice model and a
source with a solid tissue range of 41.5 n,
the geometric range is of the order of
1000 n (Table V), and the number of alveoli
exposed is of the order of 100 (Table VI).
Figure 3 shows a cross-section view of an
i
exposed volume in which the included alveoli
are all appreciably exposed. The example
exhibits an asymmetry of the order of d
that can exist because of the location of
the source within the alveolus.
The alpha flux around the source is
n
described by a 1/47TX geometrical atten-
uation where x is the distance between
source and field point. This leads to
,1
large dose rate gradients in the neighbor-
hood of a source. The fluxes computed
Cor a lest source in a lattice (Table VII)
give sonic idea of the intensities to which
the tissue in the various regions is ex-
posed. Notice that 6 orders of magnitude
are covered over the exposed volume.
Bear in mind that this lattice model
should not be taken too literally, but
rather as a representative example of an
-7-
-------
334
Table V. Geometric ranges (i'i microns) of a 5.5-MeV alpha
source in a cubical lattice.
f^-(disc) S£(arm)
1/2 maximum inflation (— = 5 ) 335
3/4 maximum inflation (^ = 7) 535
500
805
1000
1610
Table VI. Number of alveoli exposed by a 5.5-MeV alpha source
in a cubical lattice model of the DRZ.
1/2 maximum inflation (7=5) 20 33
3/4 maximum inflation (~ = ?) 53 64
/n Rd\ /Rd Rd \ /Rd Rd\ „ , ,
I ' "TFJ VST""^) \~2^'~T) Total
_\ o r __/ _y o v ^ r / \ ft r r y
15
21
68
138
4
1
i i
+ - +
1 1
+ -+-+
1 1 1
H i 4 j p
i 1 I ' i
• b*!T'- 't '. + ~~' +
J L:Vji;1:l£,'''lL.'+-llt J.'
|_i_i«i,|
i 1 1
4-4-4
1 1
1 1
1
4
' 1
+
1
_ + _
1
-4-
1
-4-
1
_+„
1
|./i
1
I
T
-4-
1
-+-
1
-4-
-4-
-4-
1
-4-
l
-4-
1
1—^*4-^ "^
t .
; ;• ^
•- t-"J«< MM
*• V»W, *V
•,..l::
. »4" T*
-4-
1
- + -
1
- + -
1
-+-
1
1
-t
4
i
-4
i
;:^
{
I
i
-4
1
--f
1
1 1
~:4-4-
& ] 1
:r;:4 h~
:;ai i
f:4- + -
1 1
J;"l,;: .V
i!) Source r:
1-1
::! 1
1 1
.-4-+-
1 1
-:+_+-
1 1
1
-+-
1
1
1
1
: |
• i -i
_-}__
:/:..'
1 •
-4-
1
1
-4-
1
-4-
1
4
1
4-
1
:1
1
i
I
4_
1
r
+^
i
4-
1
+
1 I
1 1
i T i
i ^ ^^ t^_ ^^^ i n
i i i
i i, i
*T"~~ T* — +•
1 1
+ - +
1 1
1
+
1
+
i
T
4-4
Fig. 3. An axis plane cross-section of an exposed volume in the lattice
model; R/r= 7 (three-fourths maximal inflation).
-8-
-------
Table _VII. Alpha flux i n number In /day.
335
Distance from
1/2 inflation
3/4 inflation
1 ft
1.6 X 104
1.6 X 104
lOp
1.6 X 102'
1.6 X 102
Rd
3r
14. X 10'2
5.6 X ICT2
source
Rd
2r
6.4 X 10~2
2.5 X 10"2
Rd
r
1.6 X 10"2
0.62 X 10"2
exposed volume in a specific lattice geom-
etry. It would not be representative
in a region where masses of solid tissue
occur whose characteristic size is of the
order of 40 M or more. Such masses are
not usually encountered in the deep respi-
ratory zone. From the model one can
infer an effective absorption length of
Rd/3r though many excursions can occur
to 1-1/2 times and rarely to even 3 times
that distance.
The effect of passing to a more realis-
tic model with airways and wall corruga-
tions would be to increase alveolar septal
thickness by possibly as much as 30%.
This would reduce the effective absorption
length proportionally, but the presence of
airways and wall corrugations would
increase the length of excursions, and
for active sources such as 1-^j Pu
238,
'Or
the distant alveoli exposed are probably
the most significant. In any event, the
simple lattice model gives order-of-
magnitude geometric numbers, which is
all that is required .with the present state
of the art.
Submicroscopic Structure
In order to talk about the response of
the exposed cell populations it is necessary
to say something about the tissue organiza-
tion in the interalveolar septum. All air
interfaces are covered by a single epithe-
lial layer, all blood interfaces by a single
endothelial layer. Each has its own base-
ment membrane, these membranes usually
adjoin each other, and the two tissues
with their basement membrane comprise
the thin (<~ I n) blood barrier of the res-
piratory zone. The capillaries occur in
o
an approximately hexagonal mesh (see
Fig. 4) that occupies most of the inter-
alveolar septum. One can imagine that
the nuclei of the epithelial and endothelial
cells tend to congregate in the openings of
the capillary mesh, while their thin cyto-
plasmic extrusions protect the adjacent
capillary lumen. Interspersed in the
interstitial space are the septal cells, and
tne connective tissue fibers which give
the alveoli their structural properties,
especially elasticity. Again they can be
expected to concentrate in the openings
of the mesh. ' '
i
Some simple geometrical considerations
make it reasonable to associate three
endothelial cells and two opithelial cells
with each opening in the capillary mesh.
The three endothelial cells are sufficient
to cover three capillary segments and by
associating three segments with each
opening the entire mesh can be generated.
If one conjectures that an endothelial cell
covers several segments then one is
-9-
-------
336
Fig. 4. The hexagonal array of the cap-
illary mesh.
quickly led to very complicated three-
dimensional geometries for the cell. The
two epithelial cells are sufficient to cover
the two sides of the hexagon. This assign-
ment is consistent with the volume avail-
able in the center of the mesh. Again, the
model should not be taken too literally,
but rather as an order-of-magnitude esti-
mate of cell population densitites that is
not incompatible with electron micrographs
1 *) f\ *1
of the alveolar septum. ' ' ' There are
~ 3600 capillary segments in the walls of
2
one alveolus. Since each capillary seg-
ment i^ shared by two hexagons there are
only three capillary segments countable
with each hexagon, which implies that there
are 1200 distinct, but not disjoint, hexagons
on the surface. Each of these has of the
order of three endothelial cells and two
epithelial cells; hence the entire wall has
~ 3600 endothejial and ~ 2400 epithelial
cells. Because this septum is shared, it
follows that for an interior alveolus there
are only 1800 endothelial and 1200 epithe-
lial cells per alveolus. The number of
epithelial or endothelial cells in a volume
poo
exposed by a Pu OQ particle would be
5
of the order of 10 . (At one-half maximum
inflation ~ 120,000 endothelial, ~ 80,000
epithelial; and at three-fourths maximum
inflation ~ 250,000 endothelial, —165,000
epithelial.) Septal cells have been ignored;
presumably they are less numerous.
Radiation Response of Tissue
Knowing something about the lung geom-
etry and the cell populations it is possible
to make some comments about the radia-
tion response. The carcinogenic impli-
cations of a nonuniforrn/radiation environ-
ment will depend on the response of cell
populations to the local radiation field.
Since this radiation varies over many
orders of magnitude it would not be sur-
prising if several regimes of biological
response were travorsi'd. To try to re-
late radiation level and population re-
sponse in a detailed way seems highly
speculative. A more tractable aspect of
the total problem is the loss of potentially
cancerous cells by radiation injury.
o n
Barendson ' has observed the effect of
ionizing radiations in the arrest of clone
-10-
-------
development from kidney Tj^ cells. For
alpha radiation he found the cell injury
to be irreversible with a cross-section of
the order of that of the cell nucleus. Th\;
latter result is consistent with Bloom's
observations with proton microbeams,
where a large dose to the cytoplasm did
not prevent mitosis while a small dose
to the nucleus disrupted the separation of
chromosomes. On this basis the cross-
section for mitotic arrest by alpha radia-
tion on lung tissue is taken by analogy
from Barendson's observations with the
added assumption that in all cases of
interest the number density of chromo-
somes in the nuclear volume is roughly
equal to that in the kidney cell nuclei.
Presumably the loss of mitotic capacity
is sufficient to guarantee that cells are
not potentially cancerous, which is not
to say, however, that the disorder
associated with their ultimate death may
not have some implication of enhanced
cancer risk by creating a region of trauma
as a chemical irritant might do.
The radiation is random in direction,
so a Poisson distribution applies. At a
given radiation flux the number of mitoti-
cally fertile cells will decrease exponen-
tially with a half-life of one over the flux
through the effective nuclear cross-
section. The tissue repair mechanisms of
the organism must function on a similar
or shorter time scale if the local roll
population is not to he; totally d'srurjl ocl by
the cumulative radiation dose. There are
some clues to the history of lung cells
12
after radiation. Phillips gave 2000 R
/,
of X rays to rat lungs and then followed
the tissue response for one year. He ob-
served no widespread damage for up to
three months, at which time some endo-
thelial tissue sloughed and the affected O J /
region filled with plasma cells and mast
cells. By six months the injured capillaries
were largely reopened or replaced by
collagenous deposits. In this period no
manifestation of injury was noticed in
epithelial cells. It is worth mentioning ,
that usually the shape of the alveoli was
undisturbed, which is probably accountable
to the radiation indifference of the fibrous
supporting structure.
These observations afford some idea of «
how long a cell persists after radiation
insult. During this1,vulnerable time a
cell population presents a static profile to
radiation, and loss of mitotic capability
should be cumulative. From Phillips'
work it appears mat for endothelial tissue
this time is of the order-of 100 days and
for epithelial tissue a year or more.
Note that these times may be in fact a de-
13
creasing function of dose since it is
possible that loss of mitotic capacity may
derive from several Injuries, each having
a different time scale for manifestation.
Two thousand R of X rays is, however, a
sufficiently large dose that it should give
representative numbers.
The epithelial time is probably of
239
greater interest since the Pu O? in-
duced pulmonary cancers in dogs appear
to be largely epithelial in origin. If
consideration is limited to this tissue,
Barendson's and Bloom's studies suggest
that in regions where; then: is an alpha
flux of more than 1 per year per cell
nucleus cross section the population will
lose of the order of one-half of its poten-
tial cancer cells. If there are more than
10 counts per tissue response time per
cell nucleus cross section, the population
is almost wholly depleted of potential
-11-
-------
338 cancer cells. This roughly defines the
radiation regimes of interest for a static
OO Q
source. In the example of a 1-y Pu O2
source embedded in a lattice lung at three-
fourths inflation, the flux at the furthest
o
perimeter is of the order of 90/year/(5 M) ,
2
where (5 /u) is taken to be a representative
cross-section for an epithelial nucleus.
If the response time of epithelial popula-
tions is one year or more then an alpha
s6urce of such intensity should sterilize
all populations within the exposed volume.
, At the same time the carcinogenic risk
associated with intracellular damage
should disappear as the tissue loses its
capacity for regeneration.
It would be useful to have an approxi-
mate idea of the source sizes for which
the associated radiation is not population-
lethal throughout the entire exposed vol-
ume. Ignoring the attenuation of the radi-
ation by the tissue matrix, let xe be
defined as the geometric distance beyond
which the flux is less than 1 /year/ (5 /LI) ,
i.e., the distance inside of which 63% or
more of the epithelial cells in a local
population are rendered mitotically impo-
tent before repair begins. This quantity
can be related to the source strength
and hence to a source size, s, which is
taken here to be a sphere diameter. For
Pu238O
2, xe ~ 10 s3/2 where s is in /LI
Similarly, for endothelial populations,
xen s-lQ- s3'2. Since in the lattice model
of the human lung the gcomel i ic range is
limited by the attenuation in tissue to
less than 1500 /n it is clear that unless
the source size, s, is smaller than or
of the order of 0. 25 /LI the yearly flux will
be lethal for all ephithelial populations in
the exposed volumes. The source size
condition will only be slightly less strin-
gent for endothelial populations s < 0.35 n.
239
Pu emits alphas of similar energy ,
and has a half-life that is approximately '
300 times longer. The previous consider-
no o
ations for Pu O? apply with the exception
that for equal source-strengths the source
239
diameter of Pu ' Og will scale about 7
times larger. Hence the source size
condition will be 'modified to s < ].75 /n.
Implicit in the preceding was the as-
sumption that the source was static in the
lattice for a time greater than the tissue
, i
repair time. If instead the source is
supposed to be removed in a time char-
acteristic of fast DRZ clearance, then the
exposure time of an alveolus is of the
order of one to a few days depending on its
initial separation and its position relative
to the clearance p"ath. Comparing this
with the static case it is evident that source
intensity must scale about 100 times larger
to produce similar damage; or equivalently
particles whose diameters are < 1 w will
— (
not be population-lethal throughout the
whole exposed volume. With a moving
source the exposed volume will be some-
what more extensive, but'.since the distance
traversed before reaching a ciliated air-
way is only slightly greater than the geo-
metric range, it is doiibiful if the exposed
volume would increase by an order of
magnitude.
-12-
-------
Implications
339
Finally, does this really tell us any-
thing about the carcinogenic implications \
9Q o OQQ
of Pu O0 and Pu"aO0 inhalation. Con-
£ 6
sider a particle larger than 0.25 ju that is
immobilized in the deep lung tissues.
From the geometric model of the DRZ it
is possible to make an approximate esti-
mate of the exposed volume. If one can
accept) the inferred tissue-response times
(admittedly tenuous), and the model for
cell injury by alpha radiation, then it
follows that in the absence of local shield-
ing all of the epithelial populations within
the exposed volume should be rendered
mitotically impotent by the resident par-
ticle. This is assumed to be a sufficient
condition for no cancer induction within
the exposed volume. With sources
smaller than 0.25 n the risk should in-
crease.
Next, consider the effect of possible
local responses. With a source as active
as Pu Op it may be that a macrophage
would die shortly after ingesting a particle,
and if that is the case then plaque forma-
tion would be prevented. Possibly the
source would have such a disruptive
influence on adjacent tissue that the har-
boring alveolus would become static and
fill with debris. Local edema or a shell of
denatured protein is conceivable. Almost
surely something of this sort happens and
to a considerable degree lessens the
source range. The peripheral volume will
be subjected to transient radiation dose
in the time before this local response
i
occurs. For all but the very smallest
particles, only this transient radiation
dose would be of carcinogenic significance,
the rest of the emitted radiation being so
confined in volume as to have a lethal
effect.
Similarly the particles that are cleared
quickly may produce a transient radiation
does that is disrupting but nonlethal over
part of the exposed volume. The relative
importance of two comparable particles,
one static and one cleared, is contingent
on the time scale of the dose they inflict.
This is poorly known in both cases.
If the preceding reasoning is correct,
990
2 and Pu Og, particles deposited
in the deep respiratory zone of the lung
do not constitute a carcinogenic risk
commensurate with the total energy dis-
sipated. The part of that energy that is
potentially carcinogenic is dependent on
the intensity of the source and on the time
scales of clearance and local shielding.
While it is unrealistic to scale the
carcinogenic damage to the total energy
from a static source, 1 doubt if the effects
of radiation are so well known that we
can fix the risk from the nonstatic phases
of the problem. The particle problem is
somewhat unique in that: (1) there is
enormous variation in the dose level and
dose characteristics to which different
cell populations may be exposed, and (2)
i
volumes involved are small so
-------
340
describe in a detailed way the relationship of the number of cancers per source parti-
between radiation level and carcinogenic cle as a function of source strength at rel-
tissue response. It would seem that the atively low tissue burdens. With this, a
most reasonable and hopeful approach is meaningful estimate of risk would be
to attempt an experimental determination readily accessible.
References
1. Hatch, T. F. and P. Gross. Pulmonary Deposition and Retention of Inhaled
Aerosols. New York and London, Academic Press, 1964.
2. Weibel, E. Morphometrics of the lung. In Handbook of Physiology. Section 3,
Respiration, Volume 1, W. O. Fenn and N. Rahn, eds. Washington, D. C. ,
American Physiology Society, 1964, pp. 285-307.
3. Morrow, P. E. , F. R Gibb, H. Davies, J. Mitola, D. Wood, N. Wraight, and
H. S. Campbell. The retention and fate of inhaled plutonium dioxide in dogs.
Health Phys. 13: 113-133, 1967.
t
4. Bair, W. J. , J. F. Park, and W. J. Clarke. Long-term study of inhaled plutonium
in dogs. Battelle Memorial Institute (Richland), AFWL-TW-65-214, 1966.
5. Mann, J. R. and R A. Kirchner. Evaluation of lung burden following acute
inhalation exposure to highly insoluble PuCy Health Phys. 13: 877-882, 1967.
6. Porter, K. R. and M. A. Bonneville. An Introduction to the Fine Structure of
Cells and Tissues. Philadelphia, Lea and Ferbiger, 1964.
7. Rhodin, J A. G. An Atlas of Ultrastructure. Philadelphia >:d London, W. B.
Saunders Company, 1963, pp. 86-93.
8. Barendsen, G. W. Dose-survival curves of human cells in tissue culture
irradiated with alpha-, beta-, 20-kV x- and 200-kV x-radiation. Nature 193:
1153-1155, 1962.
9. Barendsen, G. W. , H. M. D. Walter, J. F. Fowler, and D. K. Bewley. Effects
of different ionizing radiations on human cells in tissue culture. Radiation Res.
1_8: 106-119, 1963.
10. Bloom, W. Cellular responses. Rev. Modern Phys. 3J_: 21-29, 1959.
11. Sparrow, A. H , L. A. Schairer, and R. C. Sparrow.' Relationship between
nuclear volumes, chromosome numbers, and relative radiosensitivitios. Science
j.4_i_: i(i';-i(it;, i SH:;.
12. Phillips, T. L An ultrastructural study of the development oi radiation injury in
the lung. U. S. Naval Radiological Defense Laboratory, USNRDL-TR-973, 1966.
13. Jennings, F. L. ajid R. A. Turner. Radiosensitivity of epithelium and enclothelium
in the lungs (abstract). Radiation Res. 22: 201, 1964.
-14-
-------
341
Appendix I
Derivation of Parameter Values for the
Cubical Lattice Model of the DRZ
2
From Tables II and III one can infer DRZ densities of approximately 0.12 g/cm
2
and 0.08 g/cm for one-half and three-fourths maximurh inflation, respectively. The
model should reproduce these densities.
Consider a cubical lattice of side length d and finite wall thickness r, where d is
measured between midplanes of the walls, and it is assumed that d» r. If all gross
lattice dimensions are large compared with d, then surface corrections may be ignored
and the gross lattice density is
S 1.05 g/cm3 X 6 d2 £ X-, = 1.05 g/cm3 X ^ , ,
z d '
3
where the wall density is taken as 1.05 g/cm and the density of the remaining volume is
taken as zero.
2 i •
At three-fourths maximum inflation of an average adult lung Weibel gives an
alveolar radius of 140 n for an assumed spherical geometry. This implies a radius of
122 n at half maximum inflation. To choose a compatible cube dimension it seems
appropriate to require that the associated volumes be equal, in which case
d = 1.62 X (radius). These values of d together with the density relations will fix
the parameter values at d = 197 y. ~ 200 i*, r = 7.7 ju ~ 8 y. for half maximum inflation,
and d = 226 u ~ 230 u, r=5.8/u~6/u for three-fourths maximum inflation, which are
in reasonable agreement with descriptions of the alveolus.
-15-
-------
Appendix II
Derivation of the Approximate Volume Exposed by a
Point Source in a Cubical Lattice
Let d 2 cube dimension
r = thickness of a cube wall (septum)
D = geometric range of a source
R = range in tissue of source
i, j, k H indices of the 3 Cartesian axes centered at the source
8. = angle that the direction of D makes with j_th axis
m. ~ number of septal planes traversed that are perpendicular to
the _ith axis.
Assume that R > r. It is approximately true that I'
(a) m. _ m. ^ mk ^ D
cosQ. ~ cos0. ~ cos0, "" d
1 J K
These relations break down when one or two of the cost's become small in the sense
£
R'
that cosS < -5 . Consider the various possibilities:
Case 1. cos0., cosfl, are small, in which case D very nearly lies along the ith
3 K
axis. Then (aX reduces to
and since R ~ m. r, it follows that
~ i
D = R d .
Case 2. cosO. is small, in which case 1) is confined to the plane of lhc_ith and
jth axi.s. Then (a] reduces to
m. m.
_ l_ ~ _ J_ - D
cosO. ~ cos0 d
1 '• D
m. m.
and since R = - g- r + - hr- r, it follows that
. ^
-16-
-------
343
Case 3. cosd., cosd., cosd, are not small. Hence (a) holds and
l j K •
m. m. m,
R = * r + r r + r' hence
J
y-. -w 1 R ,
D = 3 T d"
-------
344
Distribution
LRL Internal Distribution
M. M. May
D. P. Geesaman 25
G. H. Higgins
H. A. Tewes
llD Berkeley
TID File 30
External Distribution
D. S. Earth
J. McBride
Southwestern Radiological Health Laboratory
Los Vegas Nev.
L. K. Bustad
University of California
School of Veterinary Medicine
Davis, Calif..
H. D. Bruner
P. F. Gustafson
H. L. Hollister
S. A. Lough
Division of Biology and Medicine
U. S Atomic Energy Commission
Washington D. C.
G. M, Dunning
Division of Operation Safety
U. S. Atomic Energy Commission
Washington, D. G.
J. S. Kelly
Division of Peaceful Nuclear Explosives
U. S. Atomic Energy Commission
Washington, D. C
R. S. Russell
Agricultural Research Council
RadiohJolOjOical Laboratory
Letcombe Regis, Wantage-, Berkshire
England
G. M. Ward ,
Animal Science Department (Dairy)
Colorado Slate University
Fort Collins, Colo.
-18-
-------
3*5
External Distribution (continued)
D. E. Bales
E. D. Harward
Radiological Health Laboratory
U. S. Public Health Service
Rockville, Md.
K. E. Cowser
T. F. Lomenick
G. M. Van Dyne
Oak Ridge National Laboratory
Oak Ridge, Tenn.
H. S. Jordan
Los Alamos Scientific Laboratory
Los Alamos, N. Mex.
R. O. McClellan
Director, Fission Product Inhalation Program
The Lovelace Foundation
Fission Products Inhalation Laboratories
Building 9200, Area Y
Sandia Base
Albuquerque, N. Mex.
E. C. Freiling
Head, Physical Chemistry Branch
U. S. Naval Radiological Defense Laboratory
San Francisco, Calif.
TID 4500 Distribution, UC-48, Biology and Medicine
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cloifd in tint lecotl
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*ny uitoi "Mio.' F'J'"ua'>1 lo rtit emcliyftl 01 coo (tact m!h ^e
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Printed in USA. Available from the Clearinghouse for Federal
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VE/la
-19-
-------
-------
347
APPENDIX II
TID-4500, UC-48
Biology and Medicine
o e
UNIVERSITY OF CALIFORNIA
UVERMORE
Bio-Medical Division
UCRL-50387, ADDENDUM
AN ANALYSIS OF THE CARCINOGENIC RISK
FROM AN INSOLUBLE ALPHA-EMITTING AEROSOL
DEPOSITED IN DEEP RESPIRATORY TISSUE:
ADDENDUM
Donald P. Geesaman
October 9, 1968
-------
348 Contents
ABSTRACT i
INTRODUCTION ....... 1
RADIATION CARCINOGENESIS AFTER INTENSE LOCAL
EXPOSURE 1
CONCLUSIONS 6'
REFERENCES ....„., . o
-111-
-------
349
AN ANALYSIS OF THE CARCINOGENIC RISK
FROM AN INSOLUBLE ALPHA-EMITTING AEROSOL
DEPOSITED IN DEEP RESPIRATORY TISSUE:
ADDENDUM
Abstract
Several experiments are reviewed in-
volving skin and lung carcinogenesis in
mammals after intense localized doses of
ionizing radiation. A high incidence of
cancer occurs fo'- the exposures described.
The observations suggest that the car-
cinogenesis is primarily mediated by in-
jury or disruption of local tissue. It is
concluded that there is a substantial
possibility of enhanced cancer risk associ-
ated with the deposition of intense ^-emitting
particulates in deep respiratory tissue.
Within this description lung cancer risks
-3 -4
as high as 10 to 10 per disruptive
source particle are indicated. The possi-
bility of this enhanced risk places the
present standards for maximum permis-
sible lung burdens in serious question
when applied to particulates such as
238 239
Pu Op and Pu , O_. It is again suggested
that in the absence of a detailed knowledge
of pulmonary carcinogenesis, the best
course of action is an experimental
determination of the risk per disruptive
Q
particle for particle burdens « 10
particles.
Introduction
The original report (UCRL-50387)
discussed lung structure and function in
relation to radiation insult from insoluble
a-emitting aerosols. Carcinogenic risk
was treated principally within the
assumption that cancer could nor originate
in a population of miloticnlly incompetent
cells. No credible riak ev:\ lunl ion was
accomplished. This addendum extends
the consideration of radiation-induced
carcinogenesis. Several high dose ex-
periments are reviewed and analyzed
relative to the evaluation of carcinogenic
risk in high dose situations. Conclusions
nvc drawn and related to the original
i (..-port.
Radiation Carcinogenesis after Intense Local Exposure
The induction of neoplasms by ionizing1 ra -
diationis observed in diverse mammalian
tissues and species. There is no comprehen-
sive theory describing these observations.
-1-
-------
^s was previously indicated, particular
sources have the potential of exposing
adjacent tissue to intense closes of radia-
tion without being organ- or organismi-
fatal. Experiments involving carcinogenesis
induced by intense local exposure are
therefore especially relevant in judging
•whether particulate sources constitute a
unique risk.
Albert's study of radiation-induced
2-4
carcinoma in rat skin gives some
quantitative description of a high dose
carcinogenic situation. Since such de-
scriptions are rare, and since Albert's
results have implications to risk analysis
in general, his experiment is outlined
here.
2
A skin area of 24 cm was exposed to
electron radiation with various depths of
maximum penetration. The dose response
curves are reproduced in Fig. 1. In all
A 0.36rnm
B 0.75 mm
• 1 .40 mm
o 1 .65 mm (suppl . data)
I l I I L-_J__J I
Surface dose — krad
Fig. 1. Tumor incidence with respect to
surface dose at'80 weeks for three
penetration depths of electrons.
(Reproduced with the permission of
Academic Press, Inc., and
Radiation Research after Fig. 5 of
Albert, Burns and IIeimbach.2)
cases the response scale at sufficiently
*
high doses was large, —1 to 5 tumors per
rat at 80 weeks after exposure. It was
noted by Albert that when the dose was
normalized to a skin depth of 0.27 mm,
the three response curves became con-
tinuous (Fig. 2). Since this depth is near
the base of the hair follicle which com-
prises the deepest reservoir of epithelial
cells of the germinal layer, it was sug-
gestive that this might be a critical region
in the observed carcinogenesis. The
suggestion gained significance from, the
7
6
S 5
a. 4
o
I 3
2
1
0
i i i i i i r
* 0.36 mm
• 0.75 mm
, I • 1 .40 mm
o 1 ,65 mm (suppl .data)
I I
12 34 56
Dose at 0.27 mm — krod
Fig. 2. Tumor incidence with respect to
the dose at a depth of 0.27 mm in
the skin at 80 weeks for three
penetration depths of electrons.
(Reproduced with the permission
of Academic Press, Inc., and
Kuchul.ioa lU-wai-ch utter I?i;;. 7
of Albert, Burns and Ileimbach.'-)
"Large" as used here describes
tumorigenic responses which are greater
than 1 tumor for 20 animals. For refer-
ence a whole body dose of 1000 R, and a
cancer probability of 50 cancers per
million per rad, implies a risk of 0.05 per
animal.
-2-
-------
observations that most of the tumors are
similar to hair follicles, and that in the
nonulcerogenic dose range the number of
tumors per rat wa? in nearly constant
ratio (1/2000 to 1/4000) with the number
of atrophied hair follicles (Figs. 3 and 4).
Thus the carcinogenesis in this experi-
ment was remarkably correlated with the
dose to and the specific damage of a
particular skin structure. When ex-
posures were made with stripe and sieve
patterns of roughly 1 mm scale, geo-
metrical effects were observed; most
notably the cancer induction in the sieve
geometry was suppressed at doses of
1700 R, but not at doses of 2300 R. .The
reduction, however, was again consistent
with the reduction in damage as charac-
terized by atrophied hair follicles.
For perspective it is valuable to relate
these observations to cellular descriptions.
Carcinogenesis in Albert's experiment is
351
E 3
0)
Q_
Fig. 3.
I
• *Atrophic follicles
20,000
16,000
12,000
JU
o
~g
o
-jr
Q-
8,000 g-
4,000
0.5
1.0
1.5
2.0
2.5
Surface dose — krad
Dose-incidence curves of skin tumors and atrophic hair follicles
for 80 weeks after uniform surface irradiations of 24 cm2 of skin
with electrons that penetrated 1.65 mm. (Reproduced with the
permission of Academic Press, Inc., and Radiation Research
after Fig. 5 of Albert, Burns, and Heimbach.4)
-3-
-------
01
CL
io
11
o o Tumors
o——oAtrophic follicles
6000
4000
2000 .a
Q.
O
Surface dose — krad
Fig. 4, Dose-incidence curves of skin tumors and atrophic follicles for
80 weeks after uniform surface irradiation of 24 cm^ of skin
with electrons that penetr'ated 0.36 mm. (Reproduced1 with the
permission of Academic Press, Inc., and Radiation Research
after Fig. 6 of Albert, Burns and Heimbach.4)
maximum in the neighborhood of 2000 R.
It is well documented in vitro and to alessei
extent in vivo that the fraction of mitotically
competent cells as measured by clonal
formation decreases in a nearly exponential
fashion with the dose. From these re-
sults a surviving mitotic fraction of
approximately 10 would be expected in a
population of ^iirmia-il epithelial rells
exposed to 200U It. Even in this pre-
ulcerative dose regime the cell population
suffers severe mitotic 'injury. It is
significant that Albert's dose response
curves show no simple relationship with
the surviving fraction of mitotically com-
petent epithelial cells. There is certainly
no exponential decrease of the response
*
in the neighborhood of D-, and, in fact,
the tumorigenesis is maximum in a dose
region where the population of mitotically
competent cellos should be initially depleted
by about 5 orders of magnitude.
To summarize this important experi-
ment, a high incidence of cancer was ob-
served after inton:;i; Inr.aL doses of i-adi'i-
tion, and the carcinogeriesis was
proportional to the damage or disordering
of a particular skin structure.
Others have observed carcinomas and
sarcomas in rats and mice after intense
''"The dose which leaves 1/e of the cells
mitotically competent.
-4-
-------
Table I. Radiation-induced skin cancers observed in rabbits, sheep, and swine.
Animals
2 rabbits
2 sheepa
? swine
Surface dose Exposed area Cancer Reference
16,000 11 (P32 plaque) , 20 cm2
•39 • 2
16,000 R (P plaque) 20 cm
19,470 AtCi-hr (Ru106 plaque) ?
1 fibrosarcoma
1 fibrosarcoma
1 karatocanthoma
1 squamous cell
carcinoma
8, 9
8, 10
11
353
aSimilar exposures at 2000 R and 8000 R with P plaques induced no observed
cancers, nor did exposures of 2000 R, 8000 R, and 16,000 R with Sr90 plaques.
exposure of the skin to ionizing radiation
(for a summary see Ref. 6). Cancer
induction is generally a frequent event in
and rats (s'ee Ref. 12), it is difficult to
derive any characterization of carcino-
genesis from these experiments. The work
these experiments. Even at elevated doses of Laskin et.al., though not specifically
such as 12,000 R of 1-MeV electrons,
BoagandGlucksmann7 induced ~5 sarcomas
n
per 100 cm in rats.
A few results for rabbits, sheep and
swine are collected in Table I. Despite
the small number of animals involved,
32
surface doses of 16,000 R from a P
plaque induced several cancers, which is
indicative that larger mammals are
similarly susceptible to skin cancer after
intense radiation insult. Again, these
gross observations,demonstrate that en-
hanced tumor incidence does occur after
very high doses.
The skin experiments are remarkable
in that a highly disruptive dose of radia-
tion to a reparable mammalian tissue
produced frequent carcinogenesis. There
is no compelling reason to believe that
respiratory tissue behaves similarly, but
with the well (looiinu-'ritecl c;u omo,<;omc
potential of human lung tissue, and the
disruptive capacity of radioactive par-
O O Q
ticulates such as Pu O0, it is reason-
^ t
able to expect that a comparable develop-
ment occurs for lung tissue. While a
number of radioactive substances have
been used to induce lung cancers in mice
involving deep respiratory tissue, does
demonstrate a source-intensity response
curve which is reproduced in Fig. 5. A
Ru -Rh cylindrical source was
implanted in the bronchi of rats, and
cancers were observed to arise from the
bronchial epithelium. The response curve
indicates a substantial response (0.07)
s?
1
o
c
01
o
_c
65
55
45
35
25
15
5
1 1
~ Median dose
Std. error +1
-1
-
—
- y
- ^/°
-•"\ 1
0.01 O.'l
Log
1 1
i e'
2.5uCi /
./nCi •
.0 uCi /
/
/
s —
/
t
1 •"'•' 1
1.0 10.0
dose — jiCi
Fig. 5. Dose response relationship in
^Ci after exposure of the
bronchial mucosa of rats to the
^-radiation of Ru106-Rh106 pellet
implants. Squamous cell carci-
noma in survivors beyond 143
days. (Reproduced with the
permission of the Journal of the
National Cancer Institute after
Fig. 2 of Laskin et_al.13)
-5-
-------
even at 0.008 /:
-------
structural and functional unity of its own,
it would not be surprising if some dis-
rupted local integrity, a disturbed order-
ing, comprises a primary pathway of
carcinogenesis. The induction of sarcomas
with inert discs of Mylar, cellophane,
17
Teflon and Millipore (Brues e_t al. ) is
indicative that such a mechanism exists.
Presumably mitotic sterilization is an
important factor in any carcinogenesis
mediated by radiation-induced tissue
injury. The functional relation of this
factor to the carcinogenic response may
be quite different from a linearity in the
surviving mitotic fraction.
While regrettably unquantitative, the
hypothesis of an injury-mediated car-
cinogenesis is suggestively descriptive.
If the respiratory zone of the lung con-
tains a structure analogous to the rat hair
follirle, and if a radioactive particulate
deposited in the respiratory zone has
the capacity to disrupt one or rr.ore of
these structures and create a precancerous
lesion, then cancel- risks of the order of
10 to 10 per particle can be expected
n
for burdens much less than 10 particles.
1 e 1 fi
Bair's work ' does not contradict
this. As well as showing a saturated
t esponse, his experiment involves particle1
o
burdens like 10 , and since this number
is comparable with the number of alveoli,
it follows that there are many overlapping
exposures. In this situation the particles
do not necessarily produce isolated effects
and the results can not be used to infer a
risk per particle applicable at lesser
burdens.
For occupational exposure the maxi-
mum permissible King burden (MPLB) ,
of Pu238 or Pu238 is 0.016 MCi.18
Assuming a particle diameter of 0.3 p,
this burden is equivalent to 3 X 10
particles of Pu " O9 or 10 particles
*j oa •«
of Pu Oo. If there is a possibility
of tumorigenic riteks of the order of
1/2000 per particle, this raises serious
doubts as to the applicability of current
MPJjB to risk judgments involving par-
ticulates. Aside from this question of
enhanced risk from disruptive particu-
lates, Bair's observation of a burden of
~0.2 /uCi in a dog with lung cancer is
precariously close to the presently pre-
scribed MPLB. Experiments at lower
oarticle burdens are crucial to defining
the risk from insoluble a-emitting
particulates.
355
-7-
-------
References
1. Geesaman, D. P. An analysis of the carcinogenic risk from an insoluble alpha-
emitting aerosol deposited in deep respiratory tissue. University of California
Lawrence Radiation Laboratory (Livermore), UCRL-50387, 1968.
2, Albert, R. E., F, J. Burns, and R. D. Heimbach. The effect of penetration
depth of electron radiation on skin tumor formation in the rat. Radiation Res.
30: 515-524, 1967.
3. Albert, R. E., P. J. Burns, and R. D. Heimbach. Skin damage and tumor
i formation from grid and sieve patterns of electron and beta radiation in the rat.
Radiation Res. 30: 525-540, 1967.
4. Albert, R. E., F. J. Burns, and R. D. Heimbach. The association between
chronic radiation damage of the hair follicles and tumor formation in the rat.
Radiation Res. 30: 590-599, 1967.
5. Withers, H. R. The dose-survival relationship for irradiation of epithelial cells
of mouse skin. Brit. J. Radiol. 40: 187-194, 1967.
6. Hulse, E. V. Tumours of the skin of mice and other delayed effects of external
an 30
beta irradiation of mice using Sr and P. Brit. J. Cancer 16: 72-86, 1962.
7. Boag, J. W. and A. Glucksmann. Production of cancers in rats by the local
application of j3-rays and of chemical carcinogens. In Progress in Radiobiology,
J. S. Mitchell, B. E. Holmes, and C. L. Smith, eds. Proceedings of the
Fourth International Conference on Radiobiology held in Cambridge, 14-17
August, 1955. Edinburgh,'Oliver and Boyd, pp. 476-479, 1956.
8. George, L. A. and L. K. Bustad. Gross effects of beta rays on the skin.
Hanford Atomic Products Operation, Biology Research Annual Report for 1956,
HW-47500, 135-141, 1957.
9. George, L. A. II, R. L. Pershing; S. Marks, and L. K. Bustad. Cutaneous
fibrosarcoma in a rabbit following beta irradiation. Hanford Atomic. Products
Operation, Biology Research Annual Report for 1959, HW-65500, 68-69, 1960.
10. Ragan, H. A., W. J. Clarke, and L,. K. Bustad. Late effects of skin irradiation.
Battelle-Northwest Laboratory Annual Report for 1965 in the Bilological Sciences,
BNWL-280, 13-14, 1966. '
11. Karagianes, M. T., E. B. Howard, and J. L. Palotay. Battelle-Northwest
Laboratory Annual Report for 1067 to (he USAKC Division of Jliology and Medicine,
Volume I, Biological Sciences, BNWL-714, 1.10-1.11, 1968.
12. Cember, H. Radiogenic lung cancer. In Progress in Experimental Tumor
Research, F. Bomburger, ed. New York, Hafner Publishing Company, Inc.
4: 251-303, 1964.
-------
13. Laskin, S. , M. Kuschner, N. Nelson, B Altshulcr, J. H. Harley, and i»T 7
M. Daniels. Carcinoma of the lung in rets exposed to the /3-radiation of intra-
bronchial ruthenium pellets. 1. Dose response relationships. J. Natl.
Cancer Inst. 31: 219-231, 1963.
14. Altshuler, B. Dosimetry from a Ru -coated platinum pellet. Radiation Res.
9: 626-632, 1958.
15. Bair, W. J., J. F. Park, and W. J. Clarke. .Long-term study of inhaled
Plutonium in dogs. Battelle Memorial Institute (Richland), AFWL-TR-65-214,
1966 (AD-631 690).
16. Park, J. F., W. J. Clarke, and W. J. Bair. Chrbnic effects of inhaled
'239
PuOg in beagles. Battelle-Northwest Laboratory Annual Report for 1967 to
the USAEC Division of Biology and Medicine, Volume I, Biological Sciences,
BNWL-714, 3.3-3.4, 1968.
17. Brues, A. M., H. Auerbach, G. M. DeRoche, and D. Grube'. Mechanisms of
carcinogenesis. Argonne National Laboratory, Biological and Medical Research
Division Annual Report for 1967, ANL-7409, 151-155, 1967.
18. Mann, J. R. and A. R. Kirchner. Evaluation of lung burden following acute
inhalation exposure to highly insoluble PuO2- Health Phys. 13: 877-882, 1967.
-9-
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EJistiibution
LRL Internal Distribution
Michael M. May
R. E. Batzel
G. H. Higgins
A. R. Tamplin 25
H. A. Tewes
D. Warner 70
D. P, Geesaman 25
TID Berkeley
TID File 30
External Distribution
D. E. Abrahamson
University of Minnesota
Minneapolis, Minn.
D. E. Bales
E. D. Harward
U. S. Public Health Service
Rockville, Md.
D. S. Earth '
J. McBride
Southwestern Radiological Health Laboratory
Las Vegas, Nev.
R. Brodine (Mrs.)
Scientist and Citizen
St. Louis, Mo.
L. K. Bustad
University of California
Davis, Calif.
K. K. Cow ;•,(-• r
T. F. Lomenick
Oak Ridge National Laboratory
Oak Ridge, Term.
-10-
-------
359
External Distribution (Continued)
G. M. Dunning
H. H. Hollister
J. S. Kelly
S. A. Lough
J. B. Storer
U. S. Atomic Energy Commission
Washington, D. C.
M. Eisenbud
New York University Medical Center
Tuxedo, N. Y.
E. C,. Freiling
U. S. Naval Radiological Defense Laboratory
San Francisco, Calif.
P. F. Gustafson
Argonne National Laboratory
Argonne, 111.
H. S. Jordan
Los Alamos Scientific Laboratory
Los Alamos, N. Mex.
B. Kahn
Public Health Service
Cincinnati, Ohio
R. O. McClellan
The Lovelace Foundation
Albuquerque, N. Mex.
E. W. Pfeiffer
University of Montana
Missoula, Mont. ,
R. S. Russell
Agricultural Research Council
Berkshire, England
G. M. Van Dyne
G. Ward
Colorado State University
Fort Collins, Colo.
TIB-4500, UC-48, Biology and Medicine
LEGAL NOTICE
This report was prepared at an account of Government JportJCttd *ert
Neither the United Stales, nor Die Commission, nor any person Klrni on behalf
ol the Commission.
A Makes any warranty or representation (stressed or implied with
respect to the accuracy completeneji. or uselultesj si Die mleimatton con
tamed in this report. Of that the use of any information apparatus, method, or
process disclosed in this report may hot rnlrmj; privately owned rifhlj, or
8 Assumes any liabilities with respect to the use ol. or lor damages
leJultinf Iron II)! us; ol any rnlwrnalrorr, apparatus, aie'Aod of process
-------
-------
or CALIFORNIA
3R1
Bio-liedical Division
LAWRENCE RADIATION LABORATORY
P.O. BOX 808
^•IVERMORE, CALIFORNIA 94S50
TELEPHONE (415) 447-1100
TELEX 34-6.107 AEC LI1L LVMR
TWX 910-386-8339 AEC LRL LVMI
November 26, 1969
Dr. John R. Totter, Director
Division of Biology and Medicine
U. S. Atomic Energy Commission
Washington, D, C. t
Dear John:
•\
We wish to continue our efforts for constructive discussions with you and
your colleagues concerning the vital matters of Atomic Energy Development and
the Public Health and Safety. We have repeatedly indicated our urgent desire
to be constructive and to apprise you at the earliest possible tine of problems
of serious nature that might be in the horizon. My colleague, Don Geesaman and
I, have one which we wish to bring to your urgent attention now and it is the
subject of this letter. '(
This problem concerns the biological hazard attendant upon the inhalation
of plutonium oxide particles. Our analysis of this problem suggests that these
particles may represent a unique carcinogenic risk—that, when the lung exposure
occurs as a result of PutX, particles, the existing maximum permissible lung
burden may be too high by orders of magnitude. If our suspicions are correct,
the AEC could be confronted with a situation similar to the uranium miners in
the plutonium industry. The enclosed report, UCHL-50J5871, ADDENDUM, is the basis
for the above statements.
Our interest' in this problem resulted from being requested to be members
of the DBM Committee of Space Nuclear Systems Radiological Safety Matters. As
you can see from the enclosed letters to Dr. Bruner, we disagreed with the
Committee's conclusions beginning in August 196?. The more we studied thel
problem the more concerned we became as evidenced by the letter to Dr. Bruner
of October 2, 1968. In this letter and the memo to Dr. Gofman we expressed
^our concern with respect to exposure of workmen in the very vital plutonium
industry. We again expressed this concern at a briefing of the,AEC Staff in
Germantovm on October 25, 1968 (copy enclosed). ' *
,i
We are calling this problem to your attention at this time because it
appears that it will soon become a subject of public debate. As a result of
the fire at Rocky Flats, Dr. E. A. 1'artell has been conducting sin enviror.npnt?il
,'jurvey to re bsr;nir>.e tho le/;;\a of l1u-239 if- cho Coluriuo ai-oa. AJ \ia I'udc-r,:; c.iud.
it, he will probably be releasing his results in December. His results will
show evidence of contamination from the Rocky Flats plant. Our impression is
that he will at that tijrfe raise the question of permissible exposure.
It is important to note that there is no official guidance concerning
exposure to these hot-particles. ICRP publication ??9, page ^» paragraph 20
states, "In the meantime there is no clear evidence to show whether, with a
given mean absorbed dose, the biological risk associated with a non-honogeneous
distribution is greater or less than the risk resulting from a more diffuse
distribution of that dose in the lung."
-------
Dr. John Totter , November 26, 1969
Now, quite obviously, vie do not i'ecl that the Division of Biology and >
Medicine can adequately support the position taken by the Committee on Space
Radiological Safety. Hopefully, the scientific community-at-large will be
more receptive to their arguments but we doubt it. At any rate, we felt
that we should call this problem to your attentibn.
i
Sincerely yours,
Arthur R. Tamplin
Bio-Medical Division
Donald P. Geesaman
Bio-Medical Division
ART:ml
Ends, as stated
cc: Dr. Seaborg
-------
APPENDIX UV
363
"PLUTONIUM AND PUBLIC HEALTH"
(A talk given at the University of Colorado
on April 19, 1970.)
(Printed with references added in
Underground Uses of Nuclear Energy,
Part 2, Hearings before the Subcommittee
on Air and Water Pollution of the
Committee on Public Works, United States
Senate, August 5, 1970.) !
(Printed with Author's Note added in
Electric Power Consumption and Human
Wei fa re, AAAS Committee on Environmental
Alterations, August 11, 1974.)
(To be published in Energy and the
Envi ronmental Crunch, eds. Firebaugh,
et. a!., Oxford University Press,*
f 1975; and in Energy and Human Welfare,
eds. Commoner, et. al., Macmillan
Publishing Company, 1975.)
Donald P. Geesaman
School of Public Affairs
University of f'linner.ota
Minneapolis, Minnesota
* copyright
-------
365
PLUTONIUM AND PUBLIC HEALTH
Donald P. Geesaman ,
Author's Note—June 1972.
On May 11, 1969 a major fire occurred at the large Rocky Flats
plutonium facility located northwest of Denver, Colorado, and operated for
the AEC by the Dow Chemical Company. For description of this fire see
AEC press releases M-121, May 20, 1969, and M-257, November 18, 1969.
,)
Consequent to this fire E.A. Martell and S.E. Poet conducted a
pilot study on the plutonium contamination of surface soils in the Rocky
Flats environs. Their results suggested an off site contamination that was
orders of magnitude larger than that which would have been expected from
the measured plutonium releases in the air effluent of the facility.
In a letter of January 13, 1970 to Glenn Seaborg, then chairman
of the AEC, and in a press release of February 24, 1970 by the Colorado
Committee on Environmental Information, Martell et al. called attention
I
to this anomalous contamination and expressed concern over it's uncertain
.,)
origin and over its significance to public health. In response the AEC fixed
the probable origin of the off site contamination as wind dispersal of pluto-
nium leaking from rusted barrels of contaminated cutting oil, and denied
r.
that cause existed for concern over hazards to public health (see AEC
press release N-22, February 18, 1970).
It was my conviction that the AEC response provided a distorted
-------
366
and inadequate representation of the possible hazards associated with the
observed off site contamination, and that the imminent large-acale commer-
cial introduction of plutonium gave this situation a precedential significance
much greater than the already considerable significance of the situation
itself. I
In April 1970 a representative of the AEC's Division of Biology and
Medicine and myself were invited to present our views at the University of
Colorado- "Plutonium and Public Health" derives from the preceding his-
tory and should be so interpreted. The presentation was to a lay audience
i,l
and was made with that expectation. Adequate referencing was added to
the written text prior to its inclusion in Underground Uses of Nuclear Energ
Part 2, Hearings before the Subcommittee on Air and Water Pollution of the
Committee on Public WoVks United States Senate^ August 5, 1970.
• As it stands the paper still represents a legitimate critique, and
the recent emphasis on plutonium as a major energy source increases the
relevance of the discussion. An updating would involve only incremental
changes, and would generally supplement rather than disturb the substantiv
\
*j'
arguments of the original paper. Hence while^ such an updating is desirabl<
it is also of sufficient marginal value that it can be properly deferred at
my discretion.
For those who are interested in reading the traditional AEC posi-
tion on tin: aubject I would suggest "Appendix 24 - Safety Cotislilornl ions in
the Operations of the Rocky Flats Plutonium Processing Plant", from
AEC Authorizing Legislation Fiscal Year 1971 - Hearings before the Joint
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387
Committee on Atomic Energy, Part 4, March 19, 1970.
Times have changed since May 1969. Then plutonium was regarded
as a military substance and was accordingly given little public attention.
Now it is much publicized as the energy source of the not too distant future.
April 1970 was a time of transition, and I felt'the strong presence of the
i
earlier tradition, and the decision to speak was not an easy one for me. '
I have had no regrets.
D. P. G.
Plutonium and Public Health , |
For the sake of completeness let me give you some background on
plutonium. It is an element that is virtually non-existent in the earth's
natural crust. In the early 19.40's it was first produced and isolated by
Dr. Seaborg and colleagues; --Dr. Seaborg is presently Chairman of the
• »
Atomic Energy Commission. Plutonium has several isotopes, the most
important being plutonium-239, which, because of its fissionable properties
and its ease of production, is potentially the best of the three fission fuels.
i
That is why it is of interest. Aside from its fissionable properties, plu-
.>.
tonium-239 is a radioactive isotope of relatively long half-life (24,000
years), hence its radioactivity is undiminished within human time .scales.
When it decays, it emits a helium nucleus of substantial energy. Becau.se
t.
of> its physical characteristics, a helium nucleus interacts strongly with
the material along its path; and as a consequence deposits iff-: energy in
a relatively short distance, --about four-hundredths of a millimeter in
solid tissue. For comparison, a typical cell dimension is about 1/4 to
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368
1/10 of that. A cell whose nucleus is intercepted by the path of such a par
ticle suffers sufficient injury that its capacity for cell division is usually
lost (Bar 'endson, A.W., 1962 and Bloom, W., 1959).
The cancer inducing potential of plutonium is well known. One
millionth of a gram injected intradermally in mice has caused cancer
\
i (lisco, H., et al., 1947); a similar .amount injected into the blood system
of dogs has induced a substantial incidence of bone cancer (Mays, C.W.,
et al., 1947), because of plutonium1 s tendency to'seek bone tissue. Fortu-
nately the body maintains a relatively effective barrier against the entry
of plutonium into the blood system. Also, bedause of the short range of
the emitted helium nuclei, the radiation from plutonium deposited on the
surface of human skin does not usually reach any relevant tissue. Unfor-
tunately the lung is more vulnerable.
i
Before,! describe why this is, I'd like to say something about the
characteristics of an aerosol. An aerosol is physically like cigarette
smoke, or fog, or cement dust. Because of their small size, the particles
comprising an aerosol remain suspended in air for long periods of time.
If an aerosol is inhaled, then, depending on its 'physical characteristics, it
•'V
may be deposited at different sites in the respiratory tree (Health Physics.
I960), "harder aerosol .sizes are usually removed by turbulence in the nose
particles deposited in the bronchial tree are cleared upward in hours by the
ciliated mucu's blanket that covers the structure. This clearance system
does not penetrate into the deep respiratory structures, the alveoli, where
the basic oxygen-carbon dioxide exchange of the lung takes place. Smaller
-------
369
particles tend to be deposited here by gravitational settling, and if they are
\
insoluble they may reside in the alveoli for a considerable time. The prob-
lem is that, under a number of conditions (Anderson, B.V., et al. , 1967;
Eraser, D.C., 1967; Kirchner, R.A., 1966; Mann, J.R., et al., 1967;
Stewart, K., 1963; Wilson, R.H. et al., 1967| plutonium tends to form
i
aerosols of a size that are preferentially deposited in deep lung tissue. ,
Plutonium dioxide, which is a principal offender, is insoluble and may be
immobilized in the lung for hundreds of days before being cleared to the
throat or to the lymph nodes around the lungs (Health Physics, 1966).
',1
An aerosol is comprised of particles of many different sizes, and
their radioactivity may differ by factors of thousands or even more. I will
simplify the argument and say that there is a class of these particles, the
largest ones deposited in the deep lung tissue, that canibe expected to have
a different pptential of cancer induction than the particles of the smaller
class. This is because they are sufficiently radioactive to disrupt cell
L
populations in the volume of cell tissue which they expose (Geesaman,
D.P., 1968a). An example might be a particle that emits 5000 helium
!
nuclei per day. It would subject between 1 and 20 alveoli to intense radi-
,.'!
ation, sufficient, to inflict MubsUintinl coll death find tissue disruption.
For reference, the alveoli are the basic structural units of the deep lung.
They are shaped and bunched roughly like hollow grapes 0.3 millimeter
e
in diameter. Their walls are ihin, a few thousandths of :i millimeter,
and they are a highly structured tissue with many cell types. Intense ex-
posure of local tissue by a radioactive particle is referred to as the hot
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370
particle problem. The question is: does such a particle have an enhanced
potential for cancer ? No on'e knows. One can argue that cancer cannot
evolve from dead cells, hence a depleted cell population must be less
carcinogenic. This is believeable, and must be true on occasion. The
facts are, though, thai intense , local doses of radiation are extremely
I
' effective carcinogens, much more so than if the energy were averaged
over a larger tissue mass (Geesaman, D.P., 1968b). Furthermore, this
can take place at high doses of radiation where only one cell in ten thousand
has retained its capacity to divide. The cancer susceptibility of lung tis-
sue to radiation has been demonstrated in many species; one can say in
general that the lung is more susceptible to inhomogeneous exposures from
particles and implants than it is to diffuse uniform radiation. Some very
careful skin experiments of Dr. Albert have indicated that tissue disrup-
tion is a very likely pathway of radioactive induction of cancer after intense
exposure (Albert, R.E., et al., 1967a, 1967b, 1967c, 1969). The experi-
ments show that the most severe tissue injury is not necessary, nor eiven
optimal, for the induction of cancer. When these notions are applied to a
i
hot particle in the lung, the possibility of one cancer fronjjt 10, 000 disrup-
i
tive particles in realistic;. Thi.s is disturbing because an appreciable
portion of the total radioactivity in a pLutonium aerosol is usually in the
large particle component.
f
Let me demonstrate what I mean. Suppose a man received a
maximum permissible lungburden for plutonium, and suppose roughly
HV'/H of the mass of the burden \\;is associated with (tie most active class
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371
of pa'rticles deposited (that is those emitting several thousand helium nuclei
per day). This is reasonable. There would be something like a thousand of
these particles and each would chronically expose 1 to 20 alveoli to intense
radiation. If the risk of cancer is like 1 in 10, 000 for one disruptive par-
ticle, then the total risk in this situation is one in ten, i.e., one man in ten
\
would develop lung cancer.
Put another way, about 1 cubic centimeter of the lung is receiving
high doses of radiation. It would not be surprising if intense exposure of
such a localized volume led to a cancer one time in ten. The question is:
if the individual volumes are separated from each other, is substantial
protection afforded? No one knows. It is much easier to find two cancers
using 50 exposures of 1 cubic centimeter each, than it is to find a couple
of cancers in 50,000 single particle exposures. Certainly the length scales
i
of injury are long enough that a disruptive carcinogenic pathway cannot be
»
disregarded for isolated hot particles (Geesaman, D.P. , 1968b).
One can look to the relevant'experience for reassurance. In an
t
experiment done at Hanford by Dr. Bair and his colleagues, beagle dogs
were given Pu ©2 lung burdens of a few hundred thousandths of a gram
" r1
(Bair, W.J., et al. , 1966; Ross, D.M., 1967). At 9 years post exposure,
or after roughly half of an adult beagle life spun, 22 of 24 deaths involved
lung cancer, usually of multiple origin. Five dogs remain alive. For
comparison, these exposures are about 100 times larger than the present
maximum permissible burdens in man.
There are two unsatisfactory aspects of this experiment. First,
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372
because all of the dogs are developing cancer, it is impossible to infer what
would happen at lower exposures; simple proportionality does, however,
suggest that present human standards are too lax by at least a factor of
ten. Second, because the radiation dose is large, with tissue injury almost
killing the dogs; and because large numbers of particles are involved, often
I
i acting in conjunction; it is improbable that the risk from disruptive particle
can be inferred. And after all, this is what we need to know, since almost
all human'exposures will involve hot particles acting independently, and if
there is a risk from these particles, it will be additive throughout the popu-
lation; --there will be no question of a threshold burden; and there will be
a possibility that a man with an undetectable burden of a few particles will
develop a cancer as a consequence. For the exposures of concern, 1000
people with 100 disruptive particles each ''ill suffer as many total cancers
i
as 10, 000 people with 10 particles each, or as 100 people with 1000 parti-
cles each.
Human experience does not give us the answer either. Plutonium
has been around for 25 years, and people have been exposed. In 1964
through 1966 contractors indicated an average total of 21 people per year
i
with over 25% of a maximum permissible burden of plutonium (Ross, D.M.,
1968) Three out of four of the.se exposures derived from inhalation. To
be reasonably useful, the documentation of exposure must go back more
than 15 years,'because of the latent period for radiation induced cancer.
In recent years documentation has improved greatly, but from early days
there is pitifully little of relevance to the hot particle problem in the lung.
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373
c •Since I have mentioned maximum permissible lung burdens, you
are aware that there is official guidance. I would like to comment on it.
The maximum permissible lung burden is established by equilibrating the
exposure from the deposited radioactive aerosol with that of an acceptable
uniform dose of x-rays. The International Commission on Radiological
protection indicates this may be greatly in eriW, and specifically states
in its publication 9, "in the meantime there is no clear evidence to show
whether, with a,given mean absorbed dose, the biological risk associated
with a non-homogeneous distribution is greater or less than the risk re-
sulting from a more diffuse distribution of that dose in the lung. " (ICRP,
1966). They are effectively saying that there is no guidance as to the risk
for non-homogeneous exposure in the lung, hence the maximum permissible
lung burden is meaningless for plutonium particles, as are the maximum
permissible air concentrations which derive from it.
So there is a hot particle problem with plutonium in the lung, and
the hot particle problem is not understood, and there is no guidance as to
I
the risk. I don't think there is any controversy about that. Let me quote
to you from Dr. K. Z Morgan's testimony in January of this year before
" J'
the Joint Committee on Atomic Energy, U.S. Congress (Morgan, K.Z.,
I960). Dr. K./,. Morgan is oru- of Ihc- United Stale;-;' I wo mornhprs to Ihe
main Committee of the International Commission on Radiological Protec-
tion; he has been a,member of the committee longer than anyone and he
is director of Health Physics Division at Oak Ridge National Laboratory.
I quote: "There are many things about radiation exposure we do not
-------
understand, and there will continue to be uncertainties until health physics
can provide a coherent theory of radiation damage. This is why some of
the basic research studies of the USAEC are so important. D.P. Geesamai
and Tamplin have pointed out recently the problems of plutonium-239 par-
ticles and the uncertainty of the risk to a man/who carries such a particle
of high specific activity in his lungs. " At the same hearing, in response
to the committee's inquiry about priorities in basic research on the biolo-
gical effects of radiation, Dr. M. Eisenbud, then Director of the New Yor!
City Environmental Protection Administration, in part replied, "For some
reason or other the particle problem has not dome upon us in quite a little
while, but it probably will one of these days. We are not much further
along on the basic question of whether a given amount of energy delivered
to a progressively smaller and smaller volume of tissue is better or worse
i
for the recipient. This is another way of asking the question of how you
»
calculate the dose when you inhale a single particle. " (Eisenbud, M., 1970
He was correct; the problem has come up again.
>
In the context of his comment it is interesting to refer to the
National Academy of Sciences, National Research Council report of 1961
"j1
on the Effects of Inhaled Radioactive Particles (U.S. NAS. NRC. 1961).
Tin1 first ncMiteiU't: iv;uls, "The poU-Miliul lur/.ard due to airborne r;u.Ho;ic!.iv
particulates is probably the least understood of the hazards associated
with atomic weapons tests, production of radioelements, and the expanding
use of nuclear energy for power production." A decade later that state-
ment is still valid. Finally let me quote Drs, Sanders, Thompson, and
-------
375
Bair from a paper given by them last October (Sanders, C.L., 1970). Dr.
Bair and his colleagues have done the most relevant plutonium oxide inha-
lation experiments. "Nonuniform irradiation of the lung from deposited
radioactive particulates is clearly more carcinogenic than uniform expo-
sure (on a total-lung dose basis), and alpha-irradiation is more carcino-
genic than beta-irradiation. The doses required for a substantial tumor
i
incidence, are very high, however, if measured in proximity to the parj
ticle; and, again, there are no data to establish the low-incidence end of
a dose-effect curve. And there is no general theory, or data on which to
base a theory, which would permit extrapolation of the high incidence por-
tion of the curve into the low incidence region. " I agree and I suggest
that in such a circumstance it is appropriate to view the standards with
extreme caution.
There is another hazardous aspect of the participate problem in
which substantial uncertainty exists. In case of an aerosol depositing on
a surface, the material may be resuspended in the air. This process is
crudely described by a quantity called a resuspension factor which is re-
markable in that it seems generally known only to within a factor of bil-
t
* <''
lions (Kathren, R.L. 1968). Undoubtedly it can be, pinpointed somewhat
better than Ihis for plulonium oxide, hut: the h at i clips I" way to rli?palch the
problem is to say there is some evidence that plutonium particles become
attached to larger particles and are therefore no longer potential aerosols.
Unfortunately there is also evidence that large particles generate aero-
dynamic turbulence, and are hence blown about more readily, and on
-------
376
being redeposited tend to knock small particles free. In relation to this,
I'd like to give you a little subjective feeling for the hazard. There is no
official guidance on surface contamination by plutonium. Two years ago, in
an effort to determine some indication of the opinions of knowledgeable'
persons with respect to environmental contamination by plutonium, a brief
t
questionaire was administered to 38 selected LRL employees (Kathren,
R.L., private communication). All were persons who were well acquainted
with the hazards of plutonium. The group consisted of 16 Hazards Control
personnel, primarily health physicists and senior radiation monitors. The
remainder were professional personnel from 6iomedical Division, Chemis-
try, and Military Applications, who had extensive experience with plutoniun
I had nothing to do with the survey, nor was I one of the members who was
queried. The conjectured situation was that their neighborhood had been
i
contaminated by plutonium oxide to levels of 0,4 microcuries per square
meter. For reference, this value is roughly ten times the highest concen-
tration Dr. Martell found east of the Rocky Flast Dow Chemical facility
(Martell, E. A., 1970), --and bear in mind that a factor of ten ia a small
difference relative to the large uncertainties as'sociatecj ,with the hazards
from plutonium contamination. Several questions were asked. One was,
would you allow your children lo play in it? £!6% said No. Should the.se
levels be decontaminated? H9% said Yes. And to what, le-vol should tin-
area be cleaned? .riO% Kuid lo liark^rouiuJ, x.rro, minimum, or by a
reduction of at least a factor of 40. This has no profound yoic-titil'ic sig-
nificance, but indicates that many pepple conversant of the ha/.ard are not
-------
377
bla£e about the levels of contamination encountered east of Rocky Flats.
Finally I would like to describe the problem in a larger context.
By the year 2000, plutonium-239 has been conjectured to be a major energy
source. Commercial production is projected at 30 tons per year by 1980,
in excess of 100 tons per year by 2000. Plutonium contamination is not an
, academic question. Unless fusion reactor feasibility is demonstrated in
the near future, the commitment will be made to liquid metal fast breeder
reactors fueled byplutonium. Since fusion reactors are presently specula-
tive, the decision for liquid metal fast breeders should be anticipated and
plutonium should be considered as a major pollutant of remarkable toxicity
and persistence. Considering the enormous economic inertia involved in
the commitment it is imperative that public health aspects be carefully and
honestly defined prior to active promotion of the industry. To live sanely
i
with plutonium one must appreciate the potential magnitude of the risk, and
be able to monitor against all significant hazards.
An indeterminate amount of plutonium has gone off site at a major
I
facility 10 miles upwind from a metropolitan area. The loss was unnoticed.
The origin is somewhat speculative as is the ultimate deposition.
.",»''
The health and safety of public and workers are protected by a
set. of standards for plutonium acknowledged to h« meaningless.
Such things make a travesty of public health, and raise .serious
questions about a hurried acceptance of nuclear energy.
-------
378
References
Albert, R.E., F.J, Burns, andR.D. Heimbach, 1967. The effect of pe-
netration depth of electron radiation on skin tumor formation in the rat.
Radiation Res. 30: 515-524, 1967a.
. Skin damage and tumor formation from grid and sieve patterns
of electron and beta radiation in the rat. Radiation Res. 30: 525-540,
1967b. '
. The association between chronic radiation damage of the hair
follicles and tumor formation in the rat. Radiation Res. 30; 590-599,
1967c.
, 1969. An evaluation by alpha-particle Bragg peak radiation of
the critical depth in the rat skin for tumor induction. Radiation Res. 39:
332-344, 1969. ,,
Anderson, B.V., and I.C. Nelson, 1967. Plutonium air concentrations
and particle size relationship in Hanford facilities. BNWL-495,
December 1B67.
Bair, W.J., J.F. Park, and W.J. Clarke, 1966. Long-term study of in-
haled plutonium in dogs.. Battelle Memorial Institute Technical Report,
AFWL-TR-65-214.
Barendson, G.W., 1962. Dose-survival curves of human cells in tissue
culture irradiated with alpha-, beta-, 20-kV x- and 200-kV x-radiation.
Nature 193j 1153-1155, 1962.
i
Bloom, W., 1959. Cellular responses. Rev. Modern Phys. 3_h 21-29, 1951
Elsenbud, M.. Panel discussion, 1'970. In Environmental Effects of Produc
Electrical Power, Phase 2. Testimony presented at Hearings before the
Joint Committee on Atomic Energy, 91st Cong. , 1970. Washington,
D.C., U.S. Gov't. Print. Off. (To be published).
Frawer, D.C., 19fi7. [[euUh physics problcui.s associated with the produc-
tion of experimental reactor fuels containing PuC^. Health Phys. 1_3: 1133-
1143, 1967.
t
Geesamai\, D.P. , 1968a. An analysis of the carcinogenic risk from an
insoluble alpha-emitting aerosol deposited iu deep respiratory tissue.
University of California Radiation Laboratory, Livermore, UCRL-50387.
-------
319
, 1968b. An analysis of the carcinogenic risk from an insoluble
alpha-emitting aerosol deposited in deep respiratory tissue; Addendum,
University of California Radiation Laboratory, Livermore, UCRL-5Q387,
Addendum.
Health Phys., 1966. Task Group—Chairman, Paul E. Morrow, Deposi-
tion and retention models for internal dosimetry of the human respiratory
tract, 12: 173-207.
I
ICRP, 1966. Recommendations of the International Commission on Radio-
logical Protection (Adopted September 17, 1965), ICRP Publication 9.
Oxford, Pergamon Press. ICRP-PUBL-9, 1966.
Kathren, R.L., 1968. Towards interim acceptable surface contamination
levels for environmental PuO2,BNWL-SA-1510.
. Battelle Northwest (private communication).
Kirchner, R.A., 1966. A plutonium particle size study in production areas
at Rocky Flats. Am. Ind. Hygiene Assoc. J. 21: 396-401, 1966.
Lisco, H., M.P. Finkel, and A.M. Brues, 1947. Carcinogenic properties
of radioactive fission products and of plutonium. Radiology 49: 361-363.
Mann, J.R., and R.A. Kirchner. Evaluation of lung bulrden following
acute inhalation exposure to highly insoluble PuOo. Health Phys. 13;
877-882, 1967.
Martell, E.A., P.D. Goldan, J. J. Kraushaar, D.W. Shea, andR.H.
Williams, 1970. Report on the Dow Rocky Flats fire: Implications of
plutonium releases to the public health and safety. Colorado Committee
for Environmental Information, Subcommittee on Rocky Flats, Boulder,
Colorado, January 13, 1970. .(Personal communication to Dr. Glenn T.
Seaborg, Chairman, Atomic Energy Commission). ' . (1
i
Mays, C .W. , et al. , 1969. Radiation-induced bone cancer in beagles.
In Mays, et al. , (eds.), Delayed Effects of Bone-Seeking Rudionuclides.
Salt Lake City, University of Utah Press.
Morgan, K.Z., Radiation standards for reactor siting. In Environmental
Effects of Producing Electrical Power, Phase 2. Testimony presented at
Hearings before the Joint Committee on Atomic Energy, 91st Cong. , 1970.
Washington, D.C., U.S. Gov't. Print. Off. (To be published).
Park, J.F., et al. , 1970. Chronic effects of inhaled 239PuO2 in beagles.
BNWL-1050, Part 1: 3.3-3.5.
-------
380
Ross, D.M. 1968, A statistical summary of United States Atomic Energy
Commission contractors' internal exposure experience, 1957-1966. In
Kornberg, H.A., andW.D. Norwood (eds.), Diagnosis and Treatment of
Deposited Radiqnuclides. Proceedings of a Symposium held at Richland,
Washington, 15-17 May 1967. N.Y., Excerpta Medica Foundation, 1968.
pp. 427-434. (CONF-670521).
Sanders, C.L., R.C. Thompson, andW.J. Bair, 1970. Lung cancer:
Dose response studies with radionuclide's. In Inhalation Carcinogensis.
Proceedings of a Biology Division, Oak Ridge National Laboratory,
conference held in Gatlinburg, Tennessee, October 8-11, 1969. M.G.
Hanna, Jr., P. Nettesheim, andJ.R. Gilbert, (eds.) U.S. Atomic Energy
Commission Symposium Series 18, 1970. pp. 285-303, (CONF-691001).
Stewart, K., 1963. The particulate material formed by the oxidation of
plutonium. In Technology, Engineering and Safety, C. Nichols, (ed.)
New York, The Macmillan Company jx^ 535-57,9, 1963.
U.S. NAS-NRC-SUBCOMM, 1961. Effects of Inhaled Radioactive Particles.
Report of the Subcommittee on Inhalation Hazards. Committee on Patho-
logic Effects of Atomic Radiation. National Academy of Sciences-National
Research Council, Washington, D.C., Publication 848. NAS-NRC/PUB-
848, 1961.
i
Wilson, R.H., andJ.L. Terry, 1967. Biological studies associated with
a field release of plutonium. In Inhaled Particles and Vapours II, C.
Davies", (ed.) Oxford, Pergamon Press, 273-290, 1967.
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UNIVERSITY O* CALIFORNIA
381
APPENDIX V
F. RADIATION LABORATORY
nOX 808
EIUIORE, CALIFORNIA 94550
TELEPHONE (415) 4.17-1100
TELEX 34-6-407 AEG LKL. LVMR
TWX 910JS6-B339 AEC LRL LVMH
July 8, 1971
Dr. Stanley M. Greenfield
Assistant Director
Environmental Protection Agency
5600 Fishers Lane
fiockville, Maryland 20852 '
i •
Re:. AEC's Draft Environmental Statement, Hocky Flats Plant
Plutonium Recovery Facility • -. . .
Dear Doctor Greenfield:. ''-/.. -
By copy of his letter to you dated Hay 271 1971, Dr. E, A. Kartell invited
my comment on the AEC's Draft Environmental Statement, Rocky Flats
Plutonium Recovery Facility, April 1971. In response, I am submitting
the-following remarks for consideration in your review of that draft
environmental statement. * .
A general comment: Plutonium is being projected as the primary energy
source of the not-too-distant future. The gravity of this circumstance
makes it appropriate that any environmental statement concerned with
plutonium should give an informative representation of the associated
hazards and uncertainties. The draft of April 1971 dqes not satisfy
this criterion. • _ ; _ ;
More specifically, the exposition in paragraph 4 of Section 2.0-is an
inadequate and unrepresentative description of the uncertainties in human
risk attendant to exposure by plutonium aerosols. Human lung tissue has a
well known carcinogenic potential under a number of situations, including
radiation exposure; the Hanford beagle study demonstrates induction of lung
cancer by plutoniura aerosols. These are sufficient basis to establish
plutonium induced lung cancer as a legitimate concern for.humans. Judged •
in this context the negative results of the cited mouse study have little
public health relevance. In addition, it requires pathological optimism
to find reassurance in the results of the Hanford beagle experiment. Dogs
were-given aerosol burdens of Ayl~lO microcuries of Pu Op- At nine years
post exposure the lung cancer response was virtually saturated and multi-
centric origin were noted in some doge. A correlation observed between initin
burden arid tirao to cancer death vac used to infer the limit burden, for no
life shortening that was mentioned in the draft statement. The exclusive
interpretation of this crude correlation to mean a practical threshhold of
burden is no more than a promotional indulgence. The observations do not
necessarily imply that a practical threshhold exists below which no plutonium
induced cancer will occur. Moreover, the range of exposures above the
inferred limit burden may in fact, be interpreted as a region of saturated
response, that is a burden regime in which cancer induction in a population
approaches 100% during a normal life span.. -The point here is that the time
-------
Dr. Greenfield -2- July 8, 1971
382
to death may be related to the burden through population depiction,
rather than through the latent period. In the former case, appreciable
cancer incidence would be anticipated at lov/er burdens. To summarize
a specivic concern with the plutonium problem: 1) under a number of
• probable circumstances plutonium forms aeoreols; 2) the physical
character of these aerosols is such that on inhalation by humans they
are preferentially deposited in the deep respiratory tissue; J) becaus
of slow clearance and because of the insolubility of the aerosol, parti
deposited in this tissue may experience long residence times (hundreds
of days); k) an appreciable mass fraction of the aerosol is associated
with particles sufficiently large that significant (^1 alveolus)
volumes of lung tissue will be exposed to intense radiation exposure
(^1000 rem) within a meaningful physiological time; 5) studies of
the effects of intense local radiation (Albert, Hulse (skin), l-.aldague
(kidney), deposition hotspots in bone seeking alpha emitters) suggest
that despite the near mitotic sterilization of the involved tissue
an enhanced carcinogenic potential may exist, in the sense that energy
dissipated in a limited volume may be far more carcinogenic than if.the
same radiation were to dissipate its energy over a larger volume.
The question is then do the larger particulates in a plutonium aerosol
lead to associated alveolar exposures that have enhanced carcinogenic
potential. If they do, then present standards can be in error by 2-3
orders of magnitude. Notice that the emphasis here is on the anomalous
risk that may be associated with a single particle; and that if any
threshold 'is relevant, it is not the dose threshold since local exposure
. are large, but rather a structural or volumetric threshold that must
be exceeded "by the physical, extent of the exposure; and finally that
this is a very special case of the low exposure problem, a case that
is peculiar to plutonium as an insoluble aerosol-forming, long lived
alpha-emitter.
In relation to the preceding, the Hanford beagle study (A/I_IO microcuri
initial lung burden) showed cancers appearing in conjunction with radiat
induced lesions. In addition, a dog having substantially less burden
was prematurely sacrificed and no lesions or cencers were found. It
would, however, be precarious to infer that absence of lesions implies
no carcinogenic potential, or equivalently that radiation induced
lesions are a necessary condition for high dose carcinogenesis. This
point is illustrated by Albert's rat skin experiment, where carcinogenes:
was optimal in a pre-ulcerative regime of less drastic radiation injury.
(I enclosed UCRL-SOjS? and GT-121 as sources of supplementary discussion'.
It would be useful to have a formal documentation of past plutonium
'.experience for humans, in order to judge the extent to which that experi?
' can be used to quantify the hazards of plutonium. In the past 2 years
the AEG has established a plutonium registry at Hanford. If any current!
useful documentation is available from the registry, I am unaware of it.
Dr. Langham at LASL has for some 25 years followed 12 humans with
burdens in excess of a MPL. It is my impression, perhaps erroneous,
that these burdens largely derive from exposures experienced'in a waste
recovery area where the plutonium aerosol was in fact a dilute solution.
If this is the case the relevance of this documentation to particulate
exposure would be speculative. ', , . • . - . ' _ . .'
-------
Independent of the biological questions, there are substantial and QQO
significant uncertainties associated with the resuspension of plutoniunK vjf
surface contamination. The subject receives essentially no comment in
the draft statement. In the case of accidental release of plutonium
with consequent contamination of an uncontrolled area, resuspension
phenomena along with carcinogenic injury will determine the hazard to
inhabitants of the area. Uncertainties in these two factors will be
important in the public determination of an acceptable level of surface
contamination, especially in the absence of official guidance for this
latter quantity. The acceptable level of contamination will in turn
determine the costs of cleanup of property and long term displacement of
people. I suggest that Dr. Kartell is more competent than myself to
discuss the physical basis of this topic.
By conjecturing essentially no releases and a substantial safety factor
in present standards, the draft statement makes the facility appear
unrealistically benign. I believe that it would be appropriate if the -
potential environmental impact were given realization by one or by both
of the following examples.
1) By conjecturing an accident release, and using present knowledge
of distribution, resuspension, deposition and lung cancer risks to estimate
the magnitudes and uncertainties of the hazards to which contiguous
Denver could be exposed. Something of this sort is done,in "Theoretical-
Possibilities and Consequences of Major Accidents in U and Pu
Fuel Fabrication and Radioisotope Processing Plants" ORNL-3^M (see
attached excerpt); and the techniques of that study could be extended
and refined for the specific case of the proposed Plutonium Recovery
Facility. The study should be developed to the point of roughly estimating
extent of human injury, scales of evacuation, costs of clean up and
evacuation as a function of plutonium exposure standards and ground
contamination criteria. Even though contamination from the May '69
fire at Rocky Flats was apparently contained, the magnitude of the fire
was sufficient to demonstrate that a major release from such an occurrence
was conceivable and hence should be considered.
2) By discussing the environmental implications, past and future,
of the previous operating history of the Rocky Flats facility. In effect,
this would mean considering the implications of the anomalous off site
contamination, discovered by Dr. Martell in 19o9» since this total
contamination was some orders of magnitude larger than the plutonium
released in the plant's integrated air and water effluent. For this
analysis, resuspensions would be related to an on site source of contamina-
tion. Uncertainties in associated human exposures and in the implications
of these exposures would be described. Significance of future resuspension
would also be defined. Such an evaluation would give a pragmatic
measure of the level of environmental protection afforded by the facility
in the past, as well as a sense of proportion for the hazard inherent
in a plutonium handling facility.
I would appreciate hearing how the EPA chooses to deal with this
environmental statement. If I can be of service to your organization,
I will cooperate in any way that I can.
Sincerely yours,
Donald Geesaman
DGjdlp •
cc: Dr. E. A. Hartell NCAR Encs UCRL-5038?, GT-121, ORNL-3^1 excerpt
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184
Thank you for the opportunity to present this testimony.
Chairman Mills: Well I am sure you can appreciate the
fact that there is a great deal of material and it is very
difficult without a written speech to really delve into the
depth of it.
Mr. Geesaman: As I say, I will have a written state-
ment for you.
Chairman Mills: I have just a few questions for you,
Professor Geesaman. In the addendum to the report that you
referred to, you made reference to the fact that the risk
for particles is more than 1x10"3, IxlO"1*, is this correct?
Correct me wherever I am wrong.
Mr. Geesaman: No, what I said was you could infer that
it could be as large as. You see what I am tying it to is
the finding of a resonance. That was the whole logic behind
what I did in my approach. First I looked at the complexity
of the situation, and said in that complexity do we have to
worry about possibilities of what, in physical terms, you
would call a resonance, an anomalous response, and then I
looked at the Albert experiment and in there I found an
anomalous response. I said as large as. I did not say --
Chairman Mills: Okay, then you go on to state that for
less than 108 particles, is that correct?
Mr. Geesaman: Yes, because that scales to the number
of alveoli, and I wanted to avoid the argument about aggrega-
tion, and because from a public health point of view what I
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385
thought was of interest was burdens at that level where many
people would have a few particles, or a chap might have a 10
or 100 picocurie burden typically.
Chairman Mills: From that, am I correct in understand-
ing that Dr. Tamplin has used 103 - 104 as a cancer risk for
particles?
Mr. Geesaman: Yes, I think that is accurate to say
that. I think, in effect, he has tied it to that resonance
of cancer production at the level of 10^ to 105 ergs which
is an unorthodox way of looking at it, but I do not think an
inaccurate way of looking at it because it ties to the
ultimate underlying physical quantity, the energy.
Chairman Mills: But, he did not go on and specify for
a number of particles of less than 108, as I recall, which
would have a different implication?
Mr. Geesaman: I cannot speak to that issue. I
apologize for my ignorance.
Chairman Mills: Are there experiments that you know of
that have been conducted in which you could test the theory
that you propose, other than the Albert experiment?
Mr. Geesaman: No, I would say that the Richmond experi-
ment was beautifully conceived, the one done by Richmond and
Anderson at Los Alamos. The results are reassuring, if you
can find security in not understanding things. I am bothered
by that experiment because they do not see any lesions at
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386
those levels of dosage. It is a well-conceived experiment.
There are some very peculiar things about it. It is an
experiment that is enormously reassuring for Syrian hamsters
who have 103 microcuries -- no, 103 microspheres injected
into such and such an artery and which then hang up in the
capillary matrix of the lung. As I stated, I consider the
results of that experiment to be very significant. I do not
know what they mean, and you probably know much better than
I what they mean, but to me they are anomalous because some
of those particles are hot and the experimenters see nothing,
and you know that that tissue is not normal tissue any
longer, -- the contiguous tissue that is. It raises the
whole question about what the nature of the appropriate time
scale in the definition of a hot particle might be. It
raises questions about whether the functional integrity of
the lung is maintained, and are cells proliferating in
there. I do not think they see any evidence of cell pro-
liferation at all or cell death. It would appear that the
tissue maintained a static profile under those exposure
limits, which is a remarkable thing, and it raises a ques-
tion that maybe hot particles have to be somewhat hotter.
Chairman Mills: Let me ask you the question from the
standpoint of, did you see any possibility of testing your
theory in the radium dial painters?
Mr. Gessaman: Dial --
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387
Chairman Mills: Dial painters.
Mr. Geesaman: I am stone deaf in one ear.
Chairman Mills: Dial painters, that is the population
of radium dial painters which is rather extensive and which
aggregates - -
Mr. Geesaman: I guess what I would say, and I cannot
speak to that very explicitly, I looked at the hot-spot
literature for bones many years ago, and then I could not
draw a conclusion. But, I think there may be information in
that literature. But, again, the length scale is different, -•
the lung has this property, at least for the length scale
for the range of an alpha particle, that it exhibits a
density of like one-eighth. So, you have an extended region
of exposure. It extends the range essentially a factor of
10 because the density is less.
Chairman Mills: Are there any other questions by the
Panel? Dr. Morgan?
Dr. Morgan: Professor Geesaman, I would like to compli-
ment you for a scholarly, thought-provoking presentation,
review and interpretation of the literature. I do have a
question about your use of the phrase "resonance incarcino-
genesis." I usually associate resonance with frequency. Do
you mean simply a mark at, say, 104 or 10s ergs, or are you
relating it to the mitotic cycle?
Mr. Geesaman: I am sorry, this goes back to my history
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388
in plasma physics. I consider a resonance to be a region,
where the response function is large. It could be, as in
the case I am thinking of, that it may depend upon more than
just one or two parameters. But, it is a region where the
carcinogenic response function is anomalously large. That
is how I used the phrase.
Dr. Morgan: It is not related to the mitotic cycle on
the --
Mr. Geesaman: There is no frequency associated with
it.
Dr. Snyder: I note that you have, I take it, tried to
analyze some of the experimental data. Now, admittedly one
will not know the particle size distribution very accurately,
but at least some approximate form of it might be known.
Generally, they say it is log normally distributed. Have
you tried to analyze the data, say, of Bair's experiments or
others of that kind in terms of this concept to see whether
you, in fact, do arrive at a number of carcinogents per
particle, and does it hang together, you see? To me, it
would seem likely that this would be related to the amount
of activity in the particle.
Mr. Geesaman: Well, I would say, yes, it would be tied
to the amount of activity, and the definition would depend
essentially on some space time conditions that you specify.
I have tried to do that. With the Bair experiment, the
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389
number of particles are large enough that you immediately
have to start talking about aggregates and how aggregates
would affect the argument. How does the response scale with
surface effect, and how would inhomogeneous and homogeneous
exposures compare, where homogeneous means homogeneous
distribution of particles, and you can go through all kinds
of geometric arguments about that, but it is not very re-
warding. It just shows that from this experiment, you
cannot get a particle response coefficient.
More interesting -- I thought what you were asking
related to the critical group of exposed people at Los
Alamos that had been followed since 1945 and '46, (and I
should say that I just got yesterday something from Dr.
Richmond that discusses that again, and which I have not
read carefully, and so my comments relate to what I have
read before). What bothers me in the discussions there is
the justification for the inclusion in the hot particle
analysis of the 12 or 14 people who were exposed in a plu-
ft tonium recovery area in which it does not seem to be clear
what the nature of the exposure was, whether it was to the
plutonyl nitrate to which the hydrogen peroxide was being
added with the formation of fog, an actual solute fog, or
whether there were low concentration plutonium solutions
present that were also fogging when ammonia hydroxide were
added. If one used the best guess size and activity
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390
distribution of particles associated with each distinct
exposure situation, I think it would give you much more
significant information.
Dr. Snyder: Well, I would tend to agree, but I doubt
if you are going to get very much information, epidemio-
logical information out of the occupational exposures, see,
because this kind of information will not be present.
Generally when a person is exposed, we find, our laboratory,
and I think in others, it is rarely or it is very difficult
to really document carefully what particle size, what chemical
form, and so on are really involved in the exposure. So,
probably I would suppose the most precise information we can
hope for in the immediate future would be from the experi-
ments on animals using mono-disperse aerosols, and if you
are aware it is only within the last couple of years that
the laboratory has achieved something like this. So, con-
sequently, we have to wait a while to see what will happen,
whether these experiments can be interpreted in this. That
is why I sort of wonder about your use of the word "meaning-
less." This was a "meaningless concept," you say, and yet
it is the only concept that we have at present to fall back
on. You see, until we have done this experimental work to
deduce what the carcinogenic potential is per particle as a
function of particle size, then we cannot very well say what
the potential is for a real exposure. That is why I somewhat
-------
39]
feel you used a disreputable term in saying, "the concept of
average dose to lung was meaningless."
Mr. Geesaman: Well --
Dr. Snyder: One uses it only because one has nothing
else to fall back on, and I think people have been aware of
many of these discrepancies and difficulties almost from the
year one.
Mr. Geesaman: Well, I do not contradict that, and my
use of the word "meaningless" is not to give umbrage, but to
give perspective, because I think in a physical sense, it is
meaningless. That is the construction I put on it, that it
does not identify with reality, and that therefore what I
would say, and this is a very conservative position, if you
could find the maximum efficiency of cancer production on a
per-energy basis, you can perhaps work away from a very
conservative position by arguing from human epidemiological
studies.
Now, it seems to me that there has been a plutonium
industry since 1950 of significant size. I have no idea of
how many people there are in that industry, but they must
scale like a thousand or several thousand, and it would seem
to me that epidemiological information is going to come in.
Dr. Snyder: As I mentioned, this epidemiological
information will be rather imprecise. You will not have a
precise knowledge of, even an approximate knowledge of how
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392
many particles were inhaled, what the distribution and sizes
were, and perhaps even the chemical form in many cases.
Chairman Mills: Any other questions?
Dr. Garner: I would like to add to what Mr. Geesaman
said. I thought that was a very refreshing presentation.
Like you, I have been very puzzled by some of the results
out of Dr. Richmond's experiment. But, Tamplin and Cochran
made much of the fact that Richmond had seen lesions. They
make much of the fact that he had described lesions that he
had said were similar to the lesions seen by Lushbaugh and
Langham, and the guy who had the plutonium particle embedded
in his skin, the ones that are often referred to as pre-
cancerous lesions, but which were, I believe, described as
similar to precancerous lesions; and Cochran and Tamplin, as
I say, go a little further. In fact, they assume that they
were precancerous lesions and deduced that later, I dare
say, cancer would have appeared in Richmond's animals.
I feel a little more reassured than you do. I do not
understand why no lesions were seen in lots of these animals,
but lesions were seen in some animals. They were not cancerous
lesions. They were not manifest as cancer, but some lesions
were seen. It was not as if they were totally negative.
Mr. Geesaman: The negative result bothers me, that in
conjunction with Dr. Little's experiment, where there was a
fairly large carcinogenic response, these are what mystify
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393
me. I did note something that might be relevant. I think
both in Dr. Bair's experiments with the Beagles and in Dr.
Little's experiment with the Syrian hamster, they talk about
the cancer appearing at the periphery of the lung. Now, I
do not know if that has any significance or not, and I do
not know how it relates to the observations made by Dr.
Richmond in his experiments. I do not know if those
particles lie at the periphery of the lung. The way my mind
works, is I look for anomalies. I feel if I can anticipate
an anomaly, then I have a sense of understanding. So that
experiment bothers me until in my mind's eye I can see some
way of clarifying it. I am troubled by it.
Dr. First: In the proceedings that took place in
Washington, the point was made that the particles that
deposit in the lung do not stay fixed in one place for a
long period of time, but, in fact, migrate under the
physical action, physiological actions of the lung. My
question is this: Would this modify your conclusions in any
way with regard to the effect of a single particle if it
were established that it moves quite rapidly in the context
that we are considering, and how does this fit in with your
analogy to the movement of trucks and bullets, a concept
which I find a little puzzling, but I hope to get it
straightened out when I read your manuscript?
Mr. Geesaman: I do get quite a little abuse on account
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394
of that example. It is strictly an energy argument. But,
as to the question of movement of particles in the lung, I
just think back to that original little monograph that I
wrote in which I tried to define the time scales and move-
ment rates that must be involved in the various clearance
modes. It seems to me that some of the material that goes
into the deep respiratory tissue is cleared rather quickly.
Now, I do not know what the mechanism for that clearance is.
I do not know if the mechanisms for that clearance mode is
really understood or not. But what I always presumed occur-
red, was that a particle was phagocytized by a macrophage,
and then a tropism or the random movement of the macrophage
cleared it to the ciliated portion of the trachial bronchial
tree.
For the slow clearance mode, if the half-lives get to
be like 500 days and the length scales are only like 300
microns or 8000 microns say at the greatest, the distance
from an alveoli to the ciliated part of the trachial bron-
chial tree, when you start putting those times with those
distances, the motion gets to be extremely slow, and what
comes to my mind is that there must be some fixing mechanism
such as the plaques, seen I think, in pneumoconiosis, there
is a fixing mechanism where for some reason the phagocytes
remain in place and a plaque forms, and ultimately the cell
dies and lyses, and then you have the release of the particle
-------
395
again, either externally where it may be cleared by the more
rapid mode, or it is cleared into the septal region and goes
into the lymph nodes. So, as I see it, there is probably a
quasi-static mode. For the motion that occurs, if motion
occurs, you have to redefine what hot particle means in
terms of the nature of the exposure in a certain time
against some cell population.
Dr. First: That is precisely my question, assuming
that this information is correct, does this modify your
analysis and conclusions? I did not ask the question as to
whether or not you believe this, but what effect this would
have on your analysis?
Mr. Geesaman: Only if the motion was very quick.
Dr. First: Supposing it is, what happens?
Mr. Geesaman: Then you may go to a more uniform
distribution.
Dr. First: Does this then nullify the argument? Is
this the key to the situation?
Mr. Geesaman: It is not the key certainly, because
ultimately you have a great spectrum of particle activities
available to you for consideration. If you look at the
various isotopes of plutonium passing from plutonium-239 up
to reactor plutonium, up to plutonium-238.
Dr. First: I think that is irrelevant.
Mr. Geesaman: It would seem to me that when you have
-------
396
reactivity variations and size variations, that you probably
are able to pick up many orders of magnitude in activity
variation.
Dr. First: Irrelevant to my question, not the problem.
Mr. Geesaman: I would be happy to answer if my small
mind is able to follow the intricacies of the question, I
will do my best to understand it.
Chairman Mills: I feel I must cut this off. It is
very informative, but we do have a long schedule. I apolo-
gize to you.
-------
397
Responses to Comments and Questions
of the Panel, Consequent to Testimony
Given at the Public Hearing on
Plutonium Standards Held by the
United States Environmental Protection Agency
in Denver, Colorado on January 10, 1975
Donald P. Geesaman
School of Public Affairs
University of Minnesota
Minneapolis, Minnesota
-------
398
1) Response to Dr. Mill's question as to the significance of the
o
qualifying condition "for particle burdens «10 particles" in the estimate
of possible risk per disruptive particle.
This qualifying condition was imposed to avoid discussion of regional
P
aggregation of disruptive particles. If there are 10 alveoli and there are
p
disruptive particle burdens «10 particles, then there should be very few
overlapping exposure fields. Moreover, this condition would include the
exposures that were judged to be of principal public health interest. For
a further remark on the question of regional aggregation, see my response to
a question of Dr. Snyder.
2) Response to Dr. Morgan's question regarding my use of the word
'resonance.'
This usage is based on the following conceptualization. Carcinogenic
response is taken as the dependent variable. The physical and biological
variables describing the exposure situation define the field of independent
variables. A subfield that describes an exposure situation of anomalously
large carcinogenic response is referred to as a resonance. I think this
usage is consistent with scientific practice.
3) In response to Dr. Snyder's objection to my description of the
existing plutonium standards (when applied to particulate exposures) as
'meaningless.'
I stand by my description. Its intent was not to give offense, but
to provide perspective.
-------
-2- 399
Applying present plutom'um standards to participate exposures carries
with it the assumption that is is proper to average focal exposures over
fictitiously large volumes in order to infer carcinogenic response. Such
averaging procedure presumes linearity and is patently erroneous when there
are qualitative differences in response between the actual and the fictitious
dose regime. Because of the activity levels of plutonium particulates, and
because of the intercession of extensive mitotic death in the exposed cell
populations, the response must be qualitatively different for the actual and
the fictitious exposure. Hence in the context of particulate exposures the
standards are scientifically meaningless. Moreover, since it can be observed
that loss of mitotic competence in cell populations does not necessarily
reduce, and may in fact greatly increase, carcinogenic potential, the
technique of dose averaging when applied to particulates need not be conservative
and is without meaning in a public health context.
I would agree that the technique has had administrative approval
which does give it an abstract procedural meaningful ness similar in character
to the emperor's new clothes.
As to my use of the word meaningless I do not feel that I went far
beyond the position taken in paragraph 210 of NCRP #39 which states:
"There are some cases in which choice of a significant
volume or area is virtually meaningless. For example,
if a particle of radioactive material fixed in either
lung or lymph rode I,MV be c-jrcipoofjnic, the averaging
of dose either over tha "lung or one cubic centimeter may
have little to do with the case."
4) In response to Dr. Snyder's enquiry, as to whether I had tried to
interpret the results of the Hanford beagle experiment in terms of the
disruptive particle hypothesis.
-------
-3-
I have, but only to the point of seeing if the observations and the
hypothesis could be made compatible. In the original Hanford beagle experiment,
exposures were just sufficiently small that death did not occur from pulmonary
insufficiency. Consequently there were large numbers of particles involved
with much regional aggregation.
One can speculate on some limiting effects of particle aggregation.
Assume that the carcinogenic potential scales like the surface area of the
disrupted region. Consider N disruptive particles each capable of exposing
a volume V with a surface S. In one case distribute the N particles so that
their effects are isolated from each other. Then the carcinogenic potential
is -v NS. In the other case distribute the N particles so that they completely
expose a volume of order NV. Then the carcinogenic potential is ^ (NV) .
The ratio of the two cases aggregated1 * Nl/3> A S1'm11ar calculation assuming the
carcinogenic potential scales like the linear dimension of the disrupted region
2/1
would have led to a ratio, carci nogeni c potenti al -i ndependent ^ N .
carcinogenic potential -aggregate
For large N, these simple hypothetical examples demonstrate that geometric
effects might have a very significant effect in reducing the carcinogenic
potential of aggregates. For an N of 10 particles the effect could be like
a factor of 100 reduction for the surface case, and a factor of 10,000
reduction for the linear case.
To end I would say that beagles have shown a substantial incidence of
bronchi olar-alveolar cancers after receiving burdans of plutom'um in the
microcurie range. The results of an extensive experimental program at lower
burdens can not help but provide useful and much needed information.
-------
-4- 401
5) Response to Dr. Gardner's comment on the differing degrees of
encouragement he and I drew from the negative results of the Los Alamos
experiment with Syrian hamsters.
In their Po-210 experiments with this species, Little et. al. demonstrated
high incidence of bronchiolar-alveolar cancer. The Los Alamos experiment
resulted not only in virtually no cancers, but, as I read the literature,
in very little evidence of injury in the tissue adjacent to the hot particles.
This is anomalous. It is also my impression from private conversation with
Dr. Bair (and I hope that I do not misrepresent him here) that in their
experience with attempts to induce pulmonary cancer in this species with various
carcinogens, they have been relatively unsuccessful. I consider these
results to be symptomatic of this general field of observation and enquiry.
There are many observations, a few well conceived experiments, a great deal
of hopeful talk, and no prevailing sense of understanding. I am troubled
that this is a sandy footage on which to site a judgment. (Note: see
amendment to this response in nest attachment.)
6) Response to Dr. Firth's question as to the applicability of the
disruptive particle hypothesis, if, in fact, there is movement of the
particulate burden.
First I would say that motion, per se, does not disqualify the
disruptive particle hypothesis. It would still be applicable if the motion
were sufficiently slow, or if a significantmass fraction or I'na participate
burden were periodically immobilized for significant times. A particle with
just sufficient activity to be disruptive, if static for a period of a month,
would become nondisruptive if it were in a state of sufficiently rapid motion.
On the other hand, a particle that was so active as to be inefficiently
disruptive if static for long periods would become more disruptive if it
-------
402
were in a state of not too rapid motion.
The preceding comments are general. I am rather uncertain as to what
you specifically have in mind, when you refer to evidence that the plutonium
moves about in the lung. It is my understanding that after deposition of
Plutonium particulates in deep respiratory tissue, there is observed a fast
and a slow clearance mode to the ciliated surfaces of the trachea! bronchial
tree. Further there is a slow clearance to the pulmonary lymph nodes.
Considering the slow mode of external clearance, the time scale is ^ 500 days,
the length scale between deposition site and ciliated surface is no greater
than a few thousand microns. Movement of several microns a day is slow
enough that it would not disqualify the hypothesis. The physical extent of
3
the exposure would scale roughly -T£ ^ lOx larger. In the light of the
existence of a rapid mode of clearance, however, it seems more likely that
the slow clearance is related to a mechanism where the material is temporarily
fixed by static or immobilized class of phayocytic cells, which on their
demise, release the material making it again accessible to the rapid mode
of clearance. As to the movement of particles which penetrate the septal
spaces, I can make little comment. The length scales then become longer, but
the long time scales for clearance to the lymph nodes, again suggest periods
of fixation. In any event, I have not heard, nor been able to conceive of,
a mechanism for the rapid wandering of particulates through the pulmonary
tissue. That there is some gradual average directed motion is believable,
that there is a rapid motion is difficult to reconcile with the long time
scales for clearance.
-------
403
February 11, 1975
AMENDMENT TO:
Testimony Concerning the Acceptability
of Existing Public Health
Guidance for Plutonium
AND TO:
Responses to Comments and
Questions of the Panel
Donald P. Geesaman
School of Public Affairs
University of Minnesota
Minneapolis, Minnesota
-------
40 ft
RE: Los Alamos Syrian Hamster Experiment
In para. 2, p. 24 of my written testimony, and in response #5 of my
responses to comments and questions of the Panel, I commented on the nearly
completed Los Alamos Syrian hamster experiment (2000 piutoniurn-loaded microspheres
per animal, eight exposure levels, ^ 70 animals per exposure level). There I
stated:
"virtually no lesions of any sort were observed in
conjunction with the piutoniurn microspheres;"
and
"The Los Alamos experiment resulted not only in
virtually no cancers, but, as I read the literature,
in very little evidence of injury in the tissue
adjacent to the hot particles."
These statements were the basis for some of my subsequent discussion of this
experiment. The statements were grounded specifically upon a recent summary
of observed results taken from "A Radiobiological Assessment of the Spatial
Distribution of Radiation Dose from Inhaled Plutonium" (HASH-1320), W. Bair,
C. Richmond, and B. Wachholz (September 1974), which stated (emphasis added):
"No aberrant clinical signs have been observed
in any of the animals that have died or have been
sacrificed to date. Blood samples have revealed
no abnormalities even after long exposures and
there have been no regional lymph node effects.
Occasionally, small accumulations of macrophages
are seen around spheres but the fibrous encapsulation
previously described for the larger more radioactive
(about 180 micron diameter) spheres (Richmond et. al.,
1970, 1974) are not seen. Two rarely occurring
tumors were observed among animals included in
Table III-C. One hamster developed an angiosarcora
of the lung after 9.5 months exposure to 2000
microspheres each containing 0.42 picocurie alpha
activity (level 2A). Another animal developed a
lung sarcoma at the same exposure level after 12
months."
(P- 19)
-------
405
and
239
"In a study of PuC^ particles administered
by intraperitoneal injection in rats, about 2% of
the plutonium was found in the vasculature of the
lung 300-500 days post-injection (Sanders, in press).
The mean lung doses from these plutonium particles
of > 0.3 vim diameter ranged from 10 to 600 rads
for three treatment levels: 0.072, 0.360 and 2.900
yCi. Of 106 rats that survived longer than 200
days (life shortening occurred in the highest dose
groups and was due to irradiation of the peritoneal
cavity), one rat in the lowest dose group died with
a bronchiolar-alveolar adenocarcinoma after 823
days. There was no other primary pulmonary neoplasia
and little evidence of cellular reaction to the
plutonium particles in the lung, even among those
cells adjacent to the particles. Inflammation,
fibrosis, and epithelial hyperplasia and metaplasia
were not observed. In general these findings agree
with the results from the current plutonium
rnicrosphere studies at Los Alamos (Richmond and
Voelz, 1972. 1973; Richmond amTSuf livan. 1974)."
(p. 20)
While I had not seen the reference, (Richmond and Sullivan, 1974), I took
the above description to be a proper representation of the experimental results,
In the past week it has come to my attention that the preceding
description is at variance with the description given in the cited supporting
reference, "Annual Report of the Biomedical and Environmental Research Program
of the LASL Health Division," C. Richmond and E. Sullivan (May 1974). I have
subsequently seen that reference and I quote here some observations on the
Syrian hamster experiment taken from the section on Biological Results
(emphasis added):
"Most of the animals placed on study early in
the program have reached the end of their normal
life span without developing significant pulmonary
lesions. During the past few months, we have
observed some histological changes in the lungs
of veryTqng-term animals (15-20 monthsy. In these
animals, an extension of bronchiolar epithelium
-------
406
-3-
into the aveolar ducts and alveoli has occurred. In
some cases, the alveoli are lined with cuboidaj or
cbj[umnar epitheljaj cells .(Pig'. V). This lesTgrTTias
been observed almost entirely in the^higher activity
Tevels (levels 4-6) and in animals given relatively
small numbers of spheres (200p-60qoTAn Tnteres ti ng
recent observation has been the identification of a
similar lesion in animals from a lower activity
group (level 3) which had been given larger numbers
of spheres of approximately 60,000 (Fig. 2). This
group of animals has been exposed only about 6 months.
A consistent observation of this lesion after
drastically different induction times could lead
to speculation that the amount of tissue irradiated
is an important element in timing of the tumorigenie
response. There has been no increase in frank tumors
observed within the past year; however, the epithelial
changes described above could be considered as
precursors of peripheral adenomas."
(P. 7)
Omitting these observations from the later report (WASH-1320) resulted in a
defective representation of the experimental results of that experiment.
In particular, considering the short life-span of the hamster, the
appearance of these late, potentially pre-cancerous, lesions implies a severe
qualification on the observation that virtually no ( ^ 10~ /particle) tumors
have occurred in the fixed particle burden Syrian hamster experiment. Moreover,
the inclusion of these observations makes the results of the experiment less
of an anomaly, and makes them much more compatible with an interpretation
based upon tissue disruptive processes and the hot particle hypothesis.
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407
Chairman Mills:
The next speaker is Dr. Edward Martell from the National
Center for Atmospheric Research.
Dr. Martell: Mr. Chairman, Members of the Panel,
Ladies and Gentlemen:
I have presented written testimony to the Panel, which
I will summarize in my oral presentation.
Before I do, I want to make a few informal remarks, and
some clarification of some remarks made earlier today about
air concentrations of Pu relative to the current standards
and Pu soil concentrations compared to natural alpha activi-
ties. I should like to mention that air concentrations of
Pu at the east fence of Rocky Flats which showed an average
of about 1% of permissible air concentrations, and rarely
exceeded 101 or more in periods of high wind conditions
were, in fact, measurements made after the Pu sources were
-------
408
covered. Now, there was a spill area of 3.3 acres. There
also was a large apron of Pu contamination between the spill
area and the east fence. The spill area was covered with a
few inches of asphalt. The large apron was covered with a
few inches of clean gravel. Only then Rocky Flats took Pu
measurements at the east fence.
Well, all that this demonstrates is the efficacy of the
cover in the two or three years subsequent to covering the
sources. The AEG Health and Safety Lab made some additional
measurements of Pu one mile further east of the fence and,
lo and behold, the concentrations were more than an order of
magnitude higher. There is a larger area of lower concen-
tration in about one square mile area between the fence and
the site of the measurements made further east. It is the
re-entrainment of soils of relatively low Pu concentration --
but very high compared to Colorado interim soil standards --
that are involved. The air concentrations showed a remark-
able increase with wind velocity. In fact, there are many
orders of magnitude variation in soil dust concentration in
Colorado surface air as a function of wind velocity. For
ranges from a few miles per hour to, say, 60 miles per hour,
we are dealing with four or five orders of magnitude in-
crease. The problems of airborne contaminants are unique in
areas of this kind. They are exceptional.
Now, earlier today we also heard that re-entrainment
-------
409
factors vary all the way from 10"3 to 10"9. I want to
comment that we are really concerned with what people
inhale, and that 10"3 is the re-entrainment factor that
applies in areas where people are working, where vehicular
traffic stirs up dusts, where farmers are plowing, and of
other activities of this sort. The Pu concentration per
gram of surface soil is not the point. If you look at the
accumulation of particles of respirable size in deep res-
piratory systems, you find that there is a selective accumu-
lation of insoluble particles of respirable size in the
chronic exposure case. I have discussed this matter in some
detail in the latter part of my written testimony.
So, let us look at what per gram of soil, the Colorado
interim standard, really implies. The plutonium is mostly
in the insoluble form and the resuspended plutonium is
between 25 and 50 percent in respirable sized particles. I
should point out that because plutonium oxide is friable, it
continually degrades in size, so that any PuC>2 that is not
small enough to be inhaled will become so, if you have
patience.
Another aspect of this is that, because of its re-
latively high alpha specific activity, there is recoil
detachment of Pu from soils. So, even though other small
particles stick to surfaces of larger soil particles, there
is always a large fraction of the alpha-emitter in the
-------
10
detached form in the re-entrained airborne material. So,
what we really want to look at is "What is the specific
concentration of plutonium in respirable size particles that
are insoluble and will accumulate in biological systems?"
And what do we see? 2 DPM. The Colorado soil standard of
two dpm Pu (approximately one picocurie) corresponds to
between 10 and 100 picocuries of Pu per gram of insoluble
soil particles that are of respirable size. Now, how much
will someone accumulate in long-term exposure to such soil
levels of Pu?
Now, we hear of all these complicated studies to
determine the Pu and soil size distributions, the re-
entrainment factors, the inhalation exposure patterns,
inhalation retention fractions, etc. This approach involves
such an accumulation of uncertainties and errors that no one
can predict what somebody will accumulate in the long-term
exposure case. But, there is a direct way to an approximate
answer. For example, Lewis and Coughlin of the Veterans
Hospital in Boston have demonstrated that the typical adult
lung contains a certain amount of nitric acid insoluble
particules that varies linearly with age. It (the lung
burden) averages a half gram in a young adult, a gram in an
adult in age 40 or so, and a gram and a half by the age of
60. Now, these are burdens of respirable particles. They
are insoluble and they are persistent. And so a soil stand-
-------
11
ard which gives you 10 picocuries to 100 picocuries per gram
of insoluble particulate, is going to give the average 40-
year-old 10 to 100 picocuries in his lung. Now, the actual
situation is worse than that, because the lung residence
times for insoluble particles has been demonstrated to be,
for plutonium, of the order of two or two and a half years
as the mean residence time. However, the residence time in
the lymph nodes and lymph circulation system are longer.
The residence time in the liver is longer, with values
ranging from 10 to 40 years quoted in the literature.
So, in the chronic exposure case, you are going to
build up higher concentrations everywhere else other than in
the lung. Now, this is one of the reasons I wonder why we
are preoccupied with the lung cancer threat from inhaled
particles. If we are concerned with exposures from working
10 to 30 years, we should look for higher Pu concentrations
in in other organs. If we are concerned with the general
public exposures, we should be overwhelmingly concerned with
the Pu risk in the organs which have the longest residence
times, and which therefore accumulate the largest amounts
and highest concentrations.
With these preliminary remarks, I would like to suggest
that any comparison of plutonium oxide, largely in insoluble
particles of respirable size, with the bulk radium in the
top foot of soil is a very simple and naive approach to the
problem, and one that just does not belong in a forum of
this kind.
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413
Basic Considerations in the Assessment of the Cancer Risks
and Standards for Internal Alpha Emitters
Edward A. Kartell
National Center for Atmospheric Research *
Box 3000
Boulder, Colorado 80303
January 10, 1975
(Statement presented at the public hearings on plutonium standards
sponsored by the United States Environmental Protection Agency, Denver,
Colorado, January 10, 1975.)
* The National Center for Atmospheric Research is sponsored by the
National Science Foundation.
-------
414
1. Introduction: The adequacy of the biomedical basis of standards for
occupational and public exposure to plutonium and other internal alpha
emitters has been widely discussed and seriously questioned
The serious uncertainties in the cancer risks attributable to internal
alpha emitters must be resolved before we are irretrievably committed
to a nuclear energy program. This is a matter of irimediate concern in
the western suburbs of Denver due to plutonium and americium contamina-
tion of surface soils in public areas around the Rocky Flats Plutonium
(9)
Plant . Many other places are similarly affected by transuranium
element contamination and its attendant cancer risks.
Recent controversy regarding the adequacy of plutonium standards
has focused on several aspects of the problem. For the cancer risks
attributable to inhaled plutonium oxide particles, for example, it has
been asked which organ—and how small a tissue volume of that organ—is
"critical" (i.e., experiences the highest cancer risk). Further debate
centers on whether the average alpha radiation dose to the critical organ
or the tumor risk attributed to a given number of individual hot plutonium
oxide particles provides the best guidance for the assessment of risks and
standards for plutonium.
Geesaman has discussed possible mechanisms of cancer induction by
hot particles and concludes that the tumorigenic risk may be as high as
1/2000 per particle for submicron particles of plutonium oxide. A recent
/ON
examination of hot particle risks by Tamplin and Cochran , based largely
on the Geesaman study, led these authors to recommend that the occupa-
tional MPLB (maximum permissible lung burden) be reduced by a factor of
115,000, to a value of 0.14 pCi. A recent study was carried out by
Bair, Richmond, and Wachholz at the request of the U.S. Atomic Energy
-------
-2-
415
Commission, with the specific objective of providing an updated review of
the evidence bearing on the problem of uniform versus nonuniform alpha
radiation dose distribution in the lung. The authors of this study take
exception to the conclusions and recommendations of Geesaman, Tamplin,
tft ft}
and Cochran ' and conclude that
"the nonuniform dose distribution of plutonium particles in
the lung is not more hazardous and may be less hazardous than
if the plutonium were uniformly distributed and that the mean
dose lung model is a radiobiologically sound basis for
establishment of plutonium standards."
Bair et al. fail to take into account the full implications of
some of the recent published results, in particular the observed higher
tumor risks for 238Pu02 than for 239Pu02, ' the apparently limited
biological response of mammal lung cells from 238Pu and 239Pu incorporated
(12 13)
into ceramic microspheres, ' and the tobacco smoke radioactivity
(14)
results . The latter results imply that as little as a few picocuries
of insoluble alpha-emitting particles in the lung may give rise to a
significant risk of lung cancer and other serious health effects in the
chronic exposure case.
On the basis of a brief review of the known effects of alpha inter-
actions with cells (below) it will become evident that alpha radiation-
induced cancer in mammals and man must be brought about by subjecting a
large number of living cells to a limited number of alpha interactions.
Thus, in principle, the highest risk would be associated with a uniform
distribution of the alpha dose, in accordance with the conclusion of
Bair et al. However, in fact, we are almost always concerned with a
highly irregular tissue distribution of alpha-emitting particles. For
hot particles, the tumor incidence must be due to the low-dose irradiation
of a large number of cells by a very small fraction of the hot particle
-------
416 -3-
burden. And for long-term exposures, unacceptably high tumor risks
appear to be associated with picocurie burdens of internal alpha emitters.
This serious possibility calls for a drastic downward revision of
permissible exposure standards for inhaled plutonium. It also is possible
that the health effects for inhaled alpha-emitting particles include
greater incidence of atherosclerosis and other degenerative diseases of
the cardiovascular system. The published evidence supporting these
conclusions is briefly reviewed below.
2. Tumor Production; The interactions of various types of radiation
with living cells and their mutagenic effects have been widely investigated,
with results that have been reviewed and summarized by Lea, Muller,
and others. When alphas interact with the chromosome or its genes in the
nucleus of a cell, the dense ionization in the track of the alpha particles
gives rise to closely spaced breaks which bring about a wide variety of
irreversible chromosome structural changes, or mutations. X-ray and yray
interactions give rise to a diffuse distribution of ions, resulting in
widely spaced invidivual breaks, most of which can undergo repair by
recombining without structural change. Thus permanent structural changes
for X-rays and y~rays are proportional to the square of the dose, with
greatly reduced incidence at low dose rates. By contrast, structural
changes resulting from alpha interactions are directly proportional to
the number of interactions and are independent of alpha interaction rates.
Thus, with regard to the production of irreversible structural changes in
cells the relative biological effectiveness of alpha radiation, compared
to X-rays and y~rays» increases markedly at lower dose rates and over
longer periods of exposure.
-------
417
For alpha interactions with cell nuclei, most of the structural
changes are lethal and lead to the mitotic death of the cell at the next
or subsequent cell division ' . However, as Lea and others have
pointed out, some cell nuclei experience only minor structural changes
(chromosome inversions, duplications, translocations, deletions, etc.)
and remain viable. However, although only a very small fraction of alpha
interactions give rise to viable mutated cells, these survive to pro-
liferate, whereas cells that suffer lethal changes are eliminated from
the cell population. Thus in the case of long-term exposure of tissue to
internal alpha emitters at low dose rates there is a cumulative increase
in the population of cells which have survived one or more chromosome
structural changes. However it is equally obvious that a cell whose
nucleus is subjected to repeated alpha interactions within the mean life
of the cell has only a negligible chance of survival.
It is likely that a radiation-induced tumor begins with the formation
of a single malignant cell characterized by a combination of two or more
chromosome changes and/or gene mutations. The alpha radiation-induced
bone tumor incidence in dogs is observed to be proportional to the square
(19)
of the alpha dose implying that a sequence of two or more low-
probability events must be involved. This is consistent with the two-
(20 21)
mutation and multiple-mutation theories of cancer ' based on the age
distribution of cancer in man. On the basis of these considerations, the
production of a malignant cell involves a sequence of events, as follows:
(1) production of a viable mutated cell; (2) clone growth from the mutated
cell; (3) production of a second viable mutation in one or more of the
clones; (4) growth of a clone of doubly-mutated cells; etc. Thus, for a
two-mutation sequence, the tumor risk may be proportional to the function
-------
418
23-2
R t T , where R is the alpha dose rate, t is the time of exposure, and
T is the mean life of the normal cell and singly mutated cell. The term
c
2
(t/T ) represents the number of cells in each clone which should be
(21)
proportional to the square of the time of exposure and the mitotic
rate (i.e., the reciprocal of T ) . Such a tumor risk relationship makes
it quite apparent that a linear extrapolation to low dose rates is not
conservative for alpha radiation-induced tumors, but rather, that there
may be a marked inverse dose rate vs risk relationship. There is an
increasing body of published experimental evidence that reflects such a
trend.
ff\ ON
Speiss and Mays observed that for 22"*Ra alpha radiation-induced
bone sarcoma in man, the tumor incidence per rad approximately doubled for
a fourfold increase in the spacing of 22"*Ra injections and that the observed
incidence of bone tumors per rad in children was nearly twice that for
(23)
adults. Upton et al. showed a significantly higher incidence of tumors
in mice for a given neutron dose at more protracted periods of exposure.
(24)
Moskalev and Buldakov showed that fractionation of the administered
239Pu dose over larger periods of time increased bone tumor induction.
The higher tumor incidence per rad for the smaller lung burdens of crushed
238PuO. microspheres observed by Sanders seems best explained by the
limited alpha irradiation of large numbers of cells by numerous very small,
mobile particles of low activity per particle (see below) . Hamsters
subjected to low alpha doses from 210Po distributed quite homogeneously in
the bronchiolar-alveolar region show a marked increase in the lung tumor
(25)
incidence per rad at very low doses and dose rates . And the incidence
of bronchial cancer in uranium miners reflects a higher tumor risk per rad
/o t \
at the lower doses for this low dose rate exposure group. The tobacco
(14)
radioactivity results indicate a significant tumor risk for the
-------
-e- 419
cumulative alpha radiation dose from 210Po in insoluble particles in the
bronchi of smokers, involving much lower dose rates.
On the basis of the above considerations, it is evident that the
tumor risk is optimized when a very large number of cells and their
descendants are subjected to only a few widely spaced alpha interactions
with the small target afforded by the cell chromosomes. This follows
necessarily from the fact that most alpha interactions with cell chromo-
somes lead to the subsequent mitotic death of the cell, as Barendsen has
shown ' . The production of a malignant cell calls for a sequence of
two or more low-probability events and thus cannot be speeded up by the
application of massive alpha doses, but rather only by subjecting a much
larger number of cells to a liraited number of interactions. Additionally,
assuming that the tumor risk to the tissue subjected to alpha irradiation
2 3 —2
is proportional to R t (T ), explained above, it is apparent that the
alpha activity concentration, or the activity per particle which is equated
to a given tumor risk, decreases with increasing time of exposure and also
that a given risk can be attributed to smaller cumulative doses when the
time of exposure t is appreciably longer than the mean life of the cell,
T . Brues and Burch both pointed out that the two-mutation theories
of carcinogenesis ' would imply an exceptionally high effectiveness
of widely spaced radiation for tumor production. It is proposed that
just such a dose-rate relationship serves to reconcile the observed
significant tumor risk in cigarette smokers with the presence of a
persistent lung burden of insoluble smoke particles involving a total
of only a few picocuries of 210Po
3. "Hot" PuO Particle Risks: If the above tentative conclusions are
correct, then the same considerations must apply in the assessment of tumor
risk for hot particles. In this connection, a preliminary consideration
-------
of the influence of specific alpha activity and particle size of the hot
alpha-emitting particles is in order.
Raabe et al. report an apparent rate of dissolution of 238PuO
in lung fluid two orders of magnitude higher than that observed for 239PuO_
particles. Such a dramatic difference in the chemical behavior of two
isotopes of plutonium is seriously inconsistent with the negligible
influence of isotope effects on the chemical kinetics of heavy elements.
Thus it seems necessary to explain this apparent solubility difference on
physical grounds. The specific activity of the 238PuO particles (~80%
of 238PuO and ~20% of 539Pu02) was about 220 times that of 239PuO . In
addition the 238Pu02 particles exhibited a very significantly lower density
than the 239PuO_ particles, indicating a highly faulted structure and
weakened intermolecular bonding for the 238PuO. particles. Fleischer
proposes that the apparently higher dissolution rate for 238PuO-
may be explained by the alpha recoil nucleus ablation of the surface
layers of the particles, with a fragmentation rate proportional to
the specific alpha disintegration rate and with variable sizes of
4
fragments ranging up to ~10 atoms. The poorer structural integrity of
the 238PuO particles may give rise to an increase in the size range of
the ejected fragments. Such small fragments, ranging up to tens of
angstroms in diameter or more, would pass readily through the 0.1 \an
diameter pores of the membrane filters used in the dissolution experi-
(29)
ments. Also, such small ablation fragments may exhibit a much higher
mobility in tissue than particles of 0.1 to 1.0 ym diameter, the size
range of particles used in most animal inhalation experiments. This
greater mobility for very small ablation fragments in tissue may explain the
more rapid rate of translocation observed for 238PuO from the lung to the liver
-------
421
. , (32,33)
and bon~. '
Another explanation for the apparently higher solubility of 238PuO
than 239PuO? is the possibility that the intense alpha radiolysis of the
lung fluid at the surface of the particles leads to the production of
chemically active free radicals which in turn react with PuCL molecules
on the particle surface. This process also would proceed at a rate
proportional to specific activity and to particle surface area. In this
case the dissolved plutonium would diffuse away from the hot particles.
However this dissolved plutonium undoubtedly would be slowly redistributed
(34)
in the lung in the same fashion as that reported by Moskalev for
inhaled soluble compounds of plutonium, resulting in a highly nonuniform
distribution with hot spots located predominantly in the subpleural region
of the lungs. This gradual conversion of the soluble plutonium compounds
to small colloidal size particles at focal points of activity may be the
result of the self-chelating properties of tetravalent plutonium in solu-
tion.
In recent studies of rat inhalation of 238PuO,j, Sanders has
demonstrated a substantially increased risk per rad for small lung burdens
of aged, "crushed" 238PuO. microspheres. In this case the inhaled
particles are smaller particles with a proportionally larger surface area.
The more rapid rate of translocation to other organs Sanders observed can be
attributed variously to the higher mobility of the smaller particles, to
the higher rate of surface ablation (or dissolution) for the increased
surface area, or both. The higher tumor incidence can be attributed to
the greater mobility and wider redistribution of the 238PuO,, microspheres
and their breakdown products, subjecting a much larger number of cells to
a limited number of alpha interactions.
-------
4 2 2 -9-
The correctness of the above interpretation is reinforced by the
results of the Los Alamos ceramic sphere experiments reported by Richmond
et al. ' and further discussed by Bair et al. In these experi-
ments, 2000 zirconium oxide microspheres of 10 ym diameter, each sphere
containing a specified amount of plutonium, were injected into the lungs
of groups of experimental animals. The total plutonium per microsphere
ranged from 0.07 to 1.6 pCi of 239Pu and from 4.3 to 59.4 pCi of Z38Pu,
with identical activity for each of the 2000 microspheres in each of
eight animal exposure groups (70 animals per group). The local dose rate,
averaged over the small tissue volume within 40 ym from the surface of the
ceramic microspheres, was ~ 17,000 rads per year for the 0.07 pCi micro-
spheres, or ~ 200,000 alpha disintegrations per year within each microgram
of irradiated tissue. The dose rate was correspondingly higher around the
microspheres of greater activity. Less than one milligram of tissue, only
one millionth of the lung, is subjected to these massive radiation doses.
The limited biological response obtained in these experiments is
consistent with expectations on the basis of Barendsen's results ' ;
the small population of cells within the alpha range around the microspheres
experiences so many alpha interactions that all cells receive chromosome
structural changes that result in their mitotic death. The 10 yro diameter
microspheres are immobile in tissue. Also, their specific alpha activity
is so low compared to pure PuO_ that their surface recoil ablation and
dissolution rates are neglibibly low. Thus in these experiments there
was no large population of cells subject to lower intensities of alpha
interactions, as was the case for Sanders' crushed 238PuO- microsphere
experiments. Richmond and Voelz observed only two lung tumors (at
9.5 months and 12 months in animals exposed to 2000 ceramic microspheres
-------
-10-
423
of 0,42 pCi 239Pu per raicrosphere) for a total of ~ 10 hot particles.
It is suggested that these two tumors may be attributed to the action of
energetic protons scattered by alpha interactions with hydrogen atoms in
4
tissue. The expected yield is one scattered proton per 10 alphas. Such
protons have energies of about 100 KeV and a range about four times that
of the alpha particle. Thus these secondary protons irradiate 63 times
as many lung cells at lower interaction rates. It is unlikely that the
two tumors observed in these experiments can be attributed to X ray or
/or
'
Y~ray irradiation for reasons indicated by Warren and Gates.
4. Critical Health Effects: It is widely recognized that inhaled in-
soluble alpha-emitting particles deposited in the lung are, in part,
translocated via the phagocytic action of macrophages to the lymph nodes
and to other sites in the reticuloendothelial system, and also via blood
leucocytes to the liver, spleen, and bone marrow. Recent experiments with
inhaled plutonium show that the pattern and rate of translocation of
plutonium from the lung to other sites are highly dependent on particle
size and specific activity, with more rapid transport of the smaller and
more active particles. Thus, it is far from obvious whether the lung,
lymph nodes, liver, bone, or other organs, or fractions thereof, should be
taken as the critical organ or critical tissue site.
It has long been known that those tissues in which there is more
active cell division suffer the earliest and most severe radiation damage
effects and that this includes the blood-forming cells in lymphatic glands
and in bone marrow. ' Such effects include the destruction of rapidly
multiplying cells that produce the blood platelets that assist in the
control of blood clotting, or reduction in the population of leucocytes
with a corresponding reduction in resistance to disease. These effects,
-------
-11-
together with the accompanying chromosome structural changes, can give rise
to the earlier incidence not only of cancers, but also of a whole range of
/ o -1 0 Q \
diseases of the cardiovascular and renal systems '
Let us review, also, the mounting evidence suggesting that inhaled
insoluble alpha-emitting particles may be the agent of atherosclerosis,
giving rise to an increased risk of death by early coronaries and
strokes. Ahterosclerosis is reported to be present in every instance of
partial or complete arterial occlusion and every case of coronary
thrombosis . Recently Benditt has proposed that the human
atherosclerotic pique is a monoclonal proliferation of a mutated cell
(41-43)
of the artery wall, and thus an arterial tumor. Elkeles has
observed anomalously high concentrations of alpha activity at the calcified
plaque sites. In addition, atherosclerosis plaques normally occur in the
main and abdominal aortas and the coronary arteries, but rarely in the
(42-44)
pulmonary arteries . This distribution suggests a respiratory origin
for the mutagenic agent. Attempts to reproduce arterial lesions in animals
by chemical, mechanical, and nutritional means have not produced plaques
similar to those of atherosclerosis in. man . However atherosclerotic
piques have been directly induced in human arteries by intensive irradiation
(45)
with X rays and radiun . There is a high incidence of early coronaries
among cigarette smokers, with a mortality rate for males who smoke two
packs or more daily that is 2 to 2.5 times that of nonsmokers with a mean
age of death some 10 to 16 years earlier. For all these reasons, it is
proposed that inhaled insoluble alpha-emitting smoke particles are very
likely to be the mutagenic agent that gives rise to atherosclerosis in
cigarette smokers. If this is the case, similar increased risk of early
coronaries is to be expected for other groups of individuals who are
occupationally or environmentally exposed to inhalation of insoluble alpha-
-------
-12-
425
emitting particles of respirable size. Attention should be addressed to
groups exposed to airborne industrial effluents that contain uranium
oxide, thorium oxide, lead-210 and polonium-210; to airborne plutonium
oxide from stack effluents, nuclear accidents, and plutonium spills; to
high levels of fallout from atmospheric nuclear tests; etc.
The first and most obvious place to look for such effects is among
past and present plutonium workers. Very significant increases in the
incidence of early coronaries as well as lung cancer and cancer at other
sites is observed among cigarette smokers with insoluble alpha-emitting
particle burdens of only a few picocuries of 210Po in the lung and
(41-43)
similar total alpha activity per 100 grams of arterial wall tissue
By comparison, plutonium workers exhibit plutonium organ burdens ranging
from a few picocuries to a few nanocuries or more ' . And although
there has been no epidemiological study of the age-incidence of heart
disease and cancer among plutonium workers, the limited published informa-
tion bearing on this question is more disturbing than reassuring. Most
often cited is the medical experience of 26 plutonium workers at Los
(49 50)
Alamos ' , usually accompanied by a statement to the effect that
none of the medical findings for this group can be attributed definitely
to internally deposited plutonium. With equal justification one may state
that most of the serious medical findings in this group can be attributed
to plutonium. One member of the original group died in the early 1950s.
Cause of death is not reported. Another died of a coronary at age 38.
A third suffered a coronary occlusion but recovered and was well compensated.
A fourth developed a hamartoma of the lung and his right lower lobe was
surgically removed in May 1971. A fifth had a melanoma of the chest wall.
A sixth had a partial gastrectomy for a bleeding ulcer. One subject
suffered loss of teeth, apparently due to damage to the lamina dura of
-------
426
the jaws (which show the earliest effects in beagles given toxid doses
of plutonium). Another subject has gout. The full medical history of
this group, now mostly in their fifties, has not yet completely unfolded.
Only 12 of these 26 plutonium workers were exposed to plutonium inhalation.
Which of the observed effects were experienced by the inhalation exposure
group? Regardless of the distribution, the medical experience of this
small group thus far provides no basis for complacency about the health
consequences of plutonium exposure.
Hanford employees and others whose autopsy tissue samples exhibited
plutonium levels in excess of 5 pCi/kg died mainly of coronary heart
disease and other cardiovascular effects and to a lesser extent of cancer
(47)
and pulmonary emphysema . On the basis of the evidence reviewed above,
it appears that atherosclerosis may be an alpha radiation induced cancer
of the artery wall. Thus coronary heart disease and other diseases of the
cardiovascular and renal system may be expected effects of inhaled plutonium
and of other insoluble alpha emitting particles. An adequate assessment
of the magnitude of such risks can only be obtained by a comprehensive
medical follow-up of all past and present plutonium workers. Until the
age distribution of these effects among plutonium workers is fully assessed,
any claim by the proponents of nuclear energy that there is little risk
associated with the MPLB (maximum permissible lung burden) of 16 nCi of
plutonium, or small fractions thereof, is totally unjustified. The growing
evidence suggests that as little as a. few picocuries of alpha activity in
the lung, in arterial tissue, and in other organs gives rise to a
significant cancer risk.
5. Discussion: The published evidence, reviewed above, clearly indicates
that a linear extrapolation to lower doses and dose rates is not conser-
vative for internal alpha emitters. The initial effects of alpha inter-
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427
actions with cell chromosomes are irreversible and thus will vary linearly
with alpha dose rate. However the cumulative effects of internal alpha
emitters give rise to an increase in the populations of mutated cells
(cells with viable structural changes in their chromosomes) and the
health consequences of such changes. Therefore the tumor incidence per
alpha disintegration must increase with decreasing dose rate. For this
reason, a given cancer risk is equated with smaller cumulative alpha
doses and with much smaller internal alpha-emitter burdens as the period
of exposure increases.
By contrast, the cellular effects of X rays and X rays are largely
reparable at low dose rates. This stems from the fact that the diffuse
distribution of ion pairs produced by such radiation results in widely
spaced single chromosome breaks that repair themselves readily. For
these reasons, the relative biological effectiveness of alpha particles
compared to X rays and \ rays increases continuously with decreasing
dose rate. Thus alpha radiation acquires a greatly increased biological
significance relative to soft radiation in the production of tumors
and other health consequences of chromosomal structural changes.
There are several other lines of evidence that reinforce the theory
that alpha interactions with cells play a unique role in human cancer
production. The distribution of cancer in the bronchi, in the lymphatic
system, in arterial tissue, and in the liver and bone involves
sites at which insoluble alpha emitters are known to accumulate.
Anomalously high concentrations of alpha activity have been observed at
the bronchial cancer sites , at cancer sites adjoining lymph glands
/ C O C O \ //l/O^
in other organs^ ' , in atherosclerosis plaques , at liver cancer
(54)
sites in Thorotrast patients , at bone tumor sites in the radium dial
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428
workers , etc. The difficulties of producing lung cancer by external
radiation have been pointed out by Warren and Gates '~ . The abscence
of cancers in muscular tissue, except at sites of Thorotrast injection
or plutonium injection, also is relevant to this issue. All of these
observations reinforce the idea that one or more of the chromosomal
structural changes that characterize a malignant cell must be brought
about by alpha interactions and not by low-intensity X rays or X rays.
In this connection, the determination of the nature of the structural
differences between the healthy and the malignant cells of each organ
could shed some light on this important question.
It is also observed that the relative significance of chemical
agents, viruses, and radiation in the incidence of human cancer is not known.
Details of the mechanisms of cancer induction by chemical agents and
viruses are poorly understood. And the proposed chemical carcinogens in
cigarette smoke and in polluted urban environments have not been demon-
strated to be carcinogenic at the low concentrations involved. For these
and other reasons discussed above, it is likely that radiation, and alpha
radiation in particular, may be the principal agent of human cancer. In
view of such a possibility, it is very disturbing to note that the U.S.
National Cancer Institute, now spending about one-half billion dollars per
year on cancer research, has completely neglected research in the field
of radiation-induced cancer.
Published evidence " indicates that atherosclerosis is a tumor
of the artery wall and that the alpha activity at the calcified plaque
site is likely to be the mutagenic agent. If so, the major causes of
death in the general population—coronary disease, other cancers, and
strokes—may in large part be attributable to internal alpha emitters from
natural and pollutant sources. If so, fallout plutonium and other
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-16-
alpha-emitting contaminants must already be contributing to increased
cancer incidence and life shortening in the general public. Cigarette
smoking causes increased risk of early coronaries, lung cancer, cancer at
other organ sites, and other health effects , with about 15 years'
reduction in life expectancy for those who regularly smoke two packs
of cigarettes or more per day (attributable to lung burdens of only about
5 pCi of 21 Po in excess of that of nonsmokers) . Fallout levels from
past atmospheric nuclear tests have given rise to plutonium organ burdens
of ~0.5 pCi/kg of lung tissue and ~0.7 pCi/kg of liver tissue in the
general public . Although these levels are only about 10 percent of the
Po organ burdens of heavy smokers, the effects may be correspondingly
greater because the total population is exposed and the inhalation
exposure begins at birth.
If the health risks attributable to fallout plutonium exceed 10
percent of the risks of heavy smoking, then inhalation exposure at ~20
times fallout (the surface soil concentration of plutonium which
corresponds to the interim soil standard adopted by the Colorado Board
of Health in 1973) would give rise to organ burdens more than twice that
of heavy smokers. Exposing children to such levels would thus be
equivalent to having them smoke four packs of cigarettes per day,
beginning at birth. This estimate assumes (as I believe to be the case)
that the inhaled, insoluble radioactive smoke particles give rise to the
serious health effects of smoking.
For the estimation of organ burdens which may result from the inhalation
of soil contaminants, it is common practice to attempt to determine the
average surface soil concentrations, the applicable resuspension factors,
inhalation exposure patterns, particle size distributions, lung re-
tention, lung clearance, translocation patterns and rates, etc. The
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430
large cumulative errors and uncertainties in the prediction of the ultimate
organ burdens from long-term exposure to contaminated surface soils and
urban dusts by such a long sequence of complex processes serve to make
this procedure an almost useless exercise. There is a more direct approach
which should give more reliable estimates. Lewis et al. show that
the adult lung burden of nitric-acid-insoluble particles increases almost
linearly with age, with about 1.5 grams per kilogram of lung tissue at
age 60. It seems reasonable to assume that individuals chronically
exposed to soil dust and urban dusts will acquire just such burdens of
the insoluble constituents in the respirable size fraction of dust
particles (i.e., particles less than ~5 p™ diameter). It should be noted
that PuO. particles are highly insoluble and friable. Experimental
measurements in the Rocky Flats area also have shown that about one-
third of the airborne plutonium which has been resuspended from soil
surfaces by wind action resides in particles of respirable size. However,
only a very small fraction of the bulk surface soil is made up of
insoluble particles of respirable size. For this reason, wind resuspension
of soils with one picocurie of plutonium per gram (the Colorado interim
standard) will give rise to an estimated 10 to 100 pCi of plutonium per
gram of insoluble airborne dust of respirable size. People exposed to
such a soil level should be expected to acquire plutonium lung burdens
of 5 to 50 pCi by age 20, or 15 to 150 pCi by age 60, with additional
amounts distributed in the lymph nodes, liver, bone, and other organs. Thus
it is far from clear that the Colorado interim soil standard is a safe and
acceptable standard.
There are, of course, a number of considerations that make it
inappropriate to equate the effects of a given burden of low specific
activity, alpha-emitting cigarette smoke particles with the same amount
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-18-
(12 13)
of alpha activity in hot particles. The Los Alamos experiments '
showed that most of the alpha dose from "hot" particles of PuO_ is wasted
in the excessive irradiation of cells within the alpha range of the hot
particle surface. Thus the high tumor risk for the hot 238PuO_ particles
in the Battelle experiment can be variously attributed to (a) the
mobility of the smaller particles, (b) the recoil ablation and/or dissolution
rates, which increase with specific activity and with surface area of hot
particles, and (c) the possible irradiation of larger numbers of cells with
scattered protons (an effect that may be significant for very hot particles) ,
Thus, the insoluble alpha emitting smoke particle, uranium oxide,
thorium oxide and other alpha-emitting particles of moderate to low specific
activity may be expected to give rise to a higher tumor risk per alpha
disintegration for a given cumulative dose. Similarly, 239Pu in mixed
fallout particles may be expected to produce more tumors per disintegration
than is the case for pure 238PuO,j and 239PuO~. However, although larger
burdens of hot particles will be required for a given tumor risk, such
risks can be expected to increase with both alpha-specific activity and with
particle surface area, and the effects should occur earlier for a given
burden, especially when smaller particles of higher specific activity
are involved.
The above considerations make it obvious that the present practice of
averaging the alpha dose over the whole lung or some arbitrary fraction
thereof is a highly questionable and grossly misleading procedure
at best.
It also should be noted that americium-241 is present in association
with plutonium contamination in the Rocky Flats area and in nuclear test
areas. In addition, curium isotopes as well as americium-241 will be
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-19-
preeent in high concentration in the nuclear fuel mixture from fission and
breeder reactors which use plutonium fuel. The chemical behavior of
americium and curium in the environment will give rise to their substantial
f c o\
uptake in the biosphere and the food chain . Thus the ingestion of
americium and curium, their uptake from the gastrointestinal tract, and
/ e Q\
their accumulation in the liver and skeletal tissue of mammals and
man will give rise to additional serious health risks. Americium and curium
ingestion will be relatively more serious than plutonium inhalation in some
environments, particularly in vegetated areas of moderate to high rainfall,
where soil resuspension processes are not very effective.
6. Recommendations; It is urged that the U.S. Environmental Protection
Agency consider and act upon each of the following recommendations, which
are called for in order to provide an improved basis for the assessment
of health risks and standards for plutonium and other actinides and to
provide a higher degree of protection from the effects of internal alpha
emitters for occupational groups and the general public through adoption
of conservative interim standards for plutonium exposure.
(1) Initiate a comprehensive interagency research program to assess
the health risks of inhaled alpha-emitting particles, with special attention
to both "hot" particles and insoluble particles of low activity per particle
(59)
(Some pertinent studies have been proposed to the EPA .)
(2) Conduct a comprehensive epidemiological health study of all past
and present plutonium workers and of all other groups which have been
exposed to the inhalation of plutonium at levels significantly above fallout
plutonium.
(3) Call upon the National Cancer Institute and the National Heart
and Lung Institute to apply an appropriate fraction of their resources to
assess the role of inhaled alpha-emitting particles on the incidence of
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433
human cancer and heart disease.
(4) Adopt more conservative occupational standards for plutonium.
A reduction of present air concentration and lung burden standards by a
factor of between 100 and 1000 appears to be in order. Better protection
should be provided for younger employees and groups exposed to possible
inhalation of finely divided and higher-specific-activity plutonium.
(5) Reduce public exposure levels of plutonium and other alpha
emitters to the practical minimum. In my view, this would limit public
exposure to airborne dusts not exceeding 0.5 pCi of alpha activity (about
one alpha disintegration per minute) per gram of nitric-acid-insoluble
particulates of respirable size. This level would result in the accumula-
tion of adult organ burdens about equal to that from fallout plutonium
On this basis the Colorado interim standard may be at least 20 times too
high.
(6) Call for a full disclosure of all past plutonium spills and
accidental releases and conduct appropriate surveys and cleanup operations.
(7) Develop standards for americium and curium, with particular
attention to their distribution in the food chain and their uptake from
the gastrointestinal tract.
(8) Give immediate attention to current plans of the U.S. Department
of Defense and the U.S. Atomic Energy Commission to resettle Eniwetok
Atoll. The high levels of plutonium and americium on these islands and
in the lagoon sediments are likely to give rise to tragic health effects
on this small native population group.
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434
-2.1-
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Chairman Mills: Thank you, Dr. Martell.
Is it your understanding that the Transuranium Registry
has more than 26 or 27 Los Alamos workers?
Dr. Martell: I find several things wrong with the
Transuranium Registry. First of all, participation on the
part of Rocky Flats wrokers has been -- the last time I
checked -- something like six percent of current employees
and very few in the past, I do not know anything about the
size of the Los Alamos group.
Chairman Mills: I think we are talking about several
hundred?
Dr. Martell: If we look at past plutonium workers, and
if we do not have any preconceived notions about how much of
a plutonium organ burden causes serious health effects, then
we should look at all past plutonium workers, at Rocky Flats
and elsewhere. I am sure that this involves between ten or
twenty thousand people, if we can find them.
Chairman Mills: But, there are more than the Los
Alamos in the Registry at the present time, is that your
understanding?
Dr. Martell: You will have to get a report from the
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Registry people. I only know that from Rocky Flats, where
we have had the largest number of plutonium workers over the
past 20 years, there is only a token and recent partici-
pation in the Transuranium Registry.
I was also going to comment that the cause of death was
given in the case of Hanford plutonium workers whose autopsy
samples were examined. You will see there they selected
only those who exceeded 5 femtocuries per gram of tissue
which is about 5 picocuries for a particular organ burden.
Most of them died relatively early of coronaries.
It is suggested that we need good statistics on this.
As I say, if it be demonstrated that the cancer agent in
cigarette smoking is the insoluble alpha-emitting particle,
then it only takes a few picocuries in a chronic exposure
case to give you a significant risk. You will note that
cigarette smokers have only 2 to 2.5 times the nonsmokers
risk of an early coronary. But the male heavy cigarette
smoker is dying 16 years earlier as the mean time of death
from a coronary than the nonsmoking male. Thus, it is not
just the relative risk because this is an important cause of
death in the general population. In these cases, you have
to look at the mean time of death. This is why we should
have a comprehensive study of all past plutonium workers,
for the benefit of future workers -- for the benefit of
getting the most responsible standards we can for them and
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for the public. I make some specific recommendations based
on my judgments in this matter in the latter part of my
written testimony. But I will not take the time to go
through it here.
Chairman Mills: I think in your statement -- I just
glanced at it -- you made the statement that the linear
hypothesis is not conservative for the insoluble plutonium
particle. Would you say the same for soluble plutonium?
Dr. Martell: I am glad you brought this up, because
one of the things I meant to point out in connection with
the difference between artificial alpha activity and
natural, is the fact that all natural activity inhaled or
ingested is in water soluble form and is soluble in body
fluids. The main sources of radium in man come from
drinking water and from radium taken up from the food chain.
And the main sources of lead-210 and polonium-210 include
surface contamination on plant foods and inhaled particles.
In all of these cases, the alpha activity, except for
plutonium activity, are in soluble form on the surface. So,
all normal alpha intake in a natural clean environment is
soluble. And all artificial alpha radioactivity that accumu-
lates in various organs, as I suggest here, are insoluble.
Plutonium oxide characteristically is insoluble. Lead-210
that comes from coal-burning effluents may be associated
with insoluble particulates. But in tobacco smoke, it is a
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high specific activity particle that is exceedingly insol-
uble in body fluids and, for that matter, in strong acids.
And so there is this characteristic difference and it makes
a tremendous difference. People living in urban areas who
are not cigarette smokers have only about 10 percent of
lead-210 and polonium-210 in their lungs in the form of
insoluble particles. But the specific alpha concentration
of those particles is about 50 to 100 times as high per
milligram as the 90 percent that is dispersed in soluble
form. Now, we do not have good measurements for heavy
smokers at various tissue sites yet. However Arthur Elkeles
showed that, in the arterial wall the alpha activity in the
insoluble form in plaques is about 5 to 100 times the
natural level. So, I am just pointing out, there is this
major difference. And therefore the pattern of cellular
interaction is completely different for natural alpha
activity in the body and for the particulate insoluble alpha
activtiy in the body. It is not just a matter of comparing,
in aerosols, the insoluble particulate alpha activity with
other insoluble particulate. In the body we must separate
these two alpha components. We see that the dissolved
natural alpha activity tissue background is a major factor,
and a major component in the nonsmoker, but even these
people have focal points that may play a significant role in
their health effects. I submit that as soon as we increase
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443
the number and activity of the insoluble particle burdens,
we may be shifting the whole pattern of diseases of old
age -- the health effects of chromosome changes the cardio-
vascular diseases --to earlier ages. This is what the
cigarette smokers' experience is telling us. The whole
pattern of health effects is rougly 15 years earlier for the
two-pack-a-day cigarette smoker. Is the same effect taking
place in the plutonium worker -- in the plutonium experience?
I submit that the AEC has not conducted the comprehensive
epidemiological study necessary to answer that question.
And I think it bears answering.
Chairman Mills: Are there any other questions?
Dr. First: I think this was in your unwritten testi-
mony, so I would like to ask you a question. Did I under-
stand you to say that 50 percent of the airborne insoluble
particles containing plutonium are a respirable fraction?
Dr. Martell: I should say 25 to 50 percent. This was
/
based on - - it was higher for the the higher wind concentra-
tions --a limited number of measurements made by the AEC
Health and Safety Lab with two different methods of measur-
ing the size distribution of airborne particles. These are
not my measurements. One expects that when a small particle
is attached to a larger soil particle, it will stay put, but
that does not seem to be the case. Either the physical
action during the process involved in retrainment detaches
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444
them, or a significant fraction may simply remain detached
because plutonium oxide is so dense and so friable. You
also have the alpha recoil process that could detach them.
Thus, in the case of plutonium and any other high specific
activity alpha-emitting particulate, you have a special, a
perhaps somewhat unusual behavior.
Dr. First: Well, this means, I take it, that the air
monitoring samples which are taking the entire sample are
represented by somewhere between 50 and 75 percent of non-
respirable particles; is that a correct deduction?
Dr. Martell: No, it is more than that. It is a very
tiny fraction, something like one part in 60 to 300 of the
bulk of the retrained soil that is in the form of insoluble
particles of respirable size, particles less than 5 or 6
microns in diameter. A large fraction of the plutonium is
in that interval, but very little of the bulk soil is in
that fraction. In addition you have the further problem
that we have to confine ourselves to the insoluble particu-
lates if we want to see what fraction of the lung deposited
material is going to persist and be accumulated there or be
transolocated to other organs.
Dr. First: What I am trying to get at is that the air
monitoring samples are total insoluble dust; is that correct?
Dr. Martell: That is total dust.
Dr. First: This is analyzed for plutonium content?
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Dr. Martell: Right.
Dr. First: Am I drawing the correct conclusion from
your statement that of the plutonium, insoluble plutonium in
the total dust, only 25 to 50 percent is in the respirable
size, and that 50 to 75 percent is nonrespirable; is that
correct?
Dr. Martell: That is correct. And in that same
connection, it is such a small fraction of the soil that is
in respirable size particles that are insolbule that, as a
consequence, one picocurie per gram of bulk soil means 10 to
100 picocuries of plutonium in insoluble particulates of
respirable size. So, the size fractionation and solubility
fractionation gives you between one and two orders of magni-
tude Pu enrichment in the size of more serious character, of
the respirable size fraction.
Dr. First: I am afraid I do not follow that. Are you
saying that the total aerosol sample is both soluble and
insoluble?
Dr. Martell: The total aerosol sample is mostly bulk
materials made up of particles too big to inhale.
Dr. First: No, I am talking about the plutonium
fraction.
Dr. Martell: The plutonium fraction, in a limited
number of measurements, was between 25 and 50 percent in
particles of respirable size. But, when viewed as activity
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concentrations in particles of respirable size, this becomes
10 to 100 picocuries per gram for a soil that, has one pico-
curie per gram. So, looking at it this way, it is easy to
see that chronic exposure to urban dust or surface soils
that have one picocurie per gram will have an expected
steady-state lung burden of 10 to 100 picocuries per gram in
the accumulated dust. As I said before, you can expect
somewhere between one-half gram and one and one-half grams
when you go from a young adult to an old adult.
Dr. First: But, this is what you have accumulated over
a period of some decades; is that right?
Dr. Martell: Yes, that is right. But, I have been
talking about chronic burdens and chronic health effects.
And so the fact that it takes time to accumulate these
burdens is beside the point. The main question is, "what
are the health consequences, and to what extent do they give
rise to higher tumor incidence and the whole pattern of
diseases of relatively old age? To what extent does it
translate these effects to increased risks at middle age?"
I think that this is the main issue here.
Chairman Mills: Doctor Taylor?
Dr. Taylor: Just one question, you are proposing or
recommending more extensive epidemiological studies of
people who have been exposed to various levels of trans-
uranics, of plutonium particulate?
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Dr. Martell: Yes.
Dr. Taylor: Now, by whatever model or hypotheses you
use for dose effect relationships, and I do not think any of
them are worth an awful lot when you come right down to it,
you ought to be able to make some kind of modest estimate as
to the size of sample that you would need to determine a
given percentage effect within given confidence levels.
This has been done for some other types of conditions other
than those elements. Have you made any such estimates as
that?
Dr. Martell: Not specifically. I have recommended the
experimental appraoches that might be used to assess the
risk in the general population, especially for the cigarette
smokers in the general population, and of course the same
considerations would apply to plutonium workers. There are
sensitive techniques for looking at the alpha activity
burdens of tissue, and you can look at insoluble particulate
per gram as well as soluble activity per gram in various
organs. If you follow the type of study that has been done
for uranium miners, and if you determine the concentration
of activity and burdens as a function of age in each group,
it is an argument against my hypothesis if there is no
correlation of tumor incidence with burden and cumulative
dose. But, on the contrary, you may develop a very nice
dose-risk relationship similar to that which they are find-
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ing for the uranium miners. There are obvious approaches
for testing this hypothesis, and I suggest that, regardless
of the merits you may think it has, I think that the stakes
are so large that we had better look at every possible
hypothesis and mechanism that we can conceive of and that
can be justified. And we had better test these in detail
before we commit ourselves to accept any one of them.
Dr. Taylor: I certainly agree with that in principle.
The uranium miners, however, represent exposures that are
enormous compared to any that I believe were involved in the
cases of plutonium exposures. x
Dr. Martell: On the contrary, I would disagree with
that because uranium miner doses have been averaged over the
actual depth of tissue in cells being irradiated, and we are
talking about doses here that range from tens to a few
hundreds of rads -- that is, cumulative alpha doses --in
some o£ the miner groups that show significant tumor in-
cidence. This dose range is way below that of the animal Pu
inhalation experiments. We are getting away from the exces-
sive waste of radiation by overradiating the cells around
the hot particles. I think that it is very easy to extra-
polate from the uranium miner dose experience and tumor
incidence to the tobacco radioactivity levels and doses and
tumor incidence. Thus, if we can extrapolate in this lower
range without difficulty, then I suggest that my interpre-
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449
tation of the hot particle risk, as due to a very small
fraction of dissolved or ablated material, also deserves a
very careful look. Now, you can test that experimentally
also. In fact, it is already apparent from the differences
for plutonium-239 and -238 -- the rate of translocation, the
tumor incidence, etc. -- all tell you that something like
this is going on. I think you could base my hypothesis on
the difference in results for the Los Alamos and Battelle
experiments. But I think that if you approach it from the
low dose rate level, then it becomes more apparent that we
are dealing with only a very tiny fraction of the dose and
the dose rate for the hot particles.
Dr. Taylor: I am not an epidemiologist, but I do not
share your optimism about the ease in which you can make
these extrapolations, and I hope that before we spend a lot
of time and effort on this, that you have a good team of
epidemiologists take a look at the planning of this type of
study, because I think too many studies of this sort have
been made largely retrospectively, and which of course they
have to be in this case, but also on not too well conceived,
in my opinion, judgments as to sample sizes, as to technology,
and so on. I do not profess myself to be any expert in
epidemiology.
Dr. Martell: I would say one thing about this, a
uranium mining group is generally a small and unsatisfactory
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450
group to study effects of this kind. But, I suggest that we
have never before had a human experiment that involved a
large number of people like the cigarette smoking experience.
And I think we should look carefully at the nature of the
changes in tumor cells, and the difference in the effective-
ness of alpha-emitters as opposed to the weak chemical
carcinogens. We ought to test this possibility, realizing
that cancer in smokers may be the result of insoluble alpha-
emitting particles. As I say, we can make an impressive
argument for alpha-induced tumors at sites other than the
bronchial epithelium in smokers. But, now there also is
another larger group than uranium miners -- the plutonium
workers. I would say, there must be somewhere between ten
and twenty thousand plutonium workers, past and present.
And if we got a larger sampling in the Transuranium Registry
and assessed the kinds of burdens plutonium workers have in
various facilities, and in various departments for various
periods of work, I think you would have a pretty good idea
what the exposures were for those you do not do autopsy
samples on. So, if we combine a good analysis program with
an epidemiological study, this group is large enough to get
some meaningful epidemiological results. It certainly ought
to be tried. Up to the present time, as you know, the
medical followup has been limited to a handful of people, 26
at Los Alamos, a few elsewhere, who have exceeded this so-
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451
called, 16 nanocurie, permissible lung burden. As a result
we do not have any statistics. We must have this before we
go much further.
Dr. Garner: If your hypothesis is correct, you should
be able to compare the inhalation of insoluble plutoniura
particles with the effect of the inhalation of tobacco
smoke? Can you tell me what concentration of plutonium in
an average person is equivalent to smoking one pack of
cigarettes a day?
Dr. Martell: \es. Then I will tcH you why this is
not a reasonable procedure. First of all, the average organ
burden of the general population of the Northern Hemisphere
of plutonium from fallout alone is about 0.5 microcurie per
killogram of lung tissue, and 0.7 picocuries per killogram
of liver tissue. We already have got this. Now, this is
about 10 percent of the typical heavy smoker's burden. And
if the above agrument is correct, fallout levels in man are
already contributing significantly to cancer and other
diseases of old age. In other words, it appears that, in
the pre-atomic age, people who lived in clean rural environ-
ments would be expected to live a lot longer. I will not
compare them directly, I will not equate a picocurie of
plutonium in a hot particle with a picocurie of polonium-210
in smoke, because, you see, there is no waste of alpha
radiation in the low activity smoke particle. I would say
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452
that I would equate similar burdens of uranium oxide and
thorium oxide and certain alpha-emitters in industrial
pollutants with the smoker particles. But, I think it would
take something like 100 times as much plutonium-239 to have
the same effect because you are wasting so much of the
radiation instead of dispersing it in tissue with a large
population of particles. Now, as you go to very much higher
specific activity particles, however, or if you go to smaller
particles of higher specific activity, then the surface
ablation and dissolution rates go up. Thus, you irradiate
many more cells and you get a more rapid translocation. So,
you will have a higher risk in all organs.
On this basis, I would say that perhaps plutonium-239
is somewhere near the minimum in tumor risk among alpha-
emitters. If we come to lower activity particles, there is
a higher tumor risk per alpha disintegration by my hypo-
thesis, which is, simply, the old somatic mutation theory of
carcinogenesis. At the other extreme, for the hotter par-
ticles, you have a population of high specific activity
particles, generating small fragments and molecular dis-
persed material which can migrate through tissue and
irradiate many cells without an excessive dose. Now, I
think that is the key. My own conclusion, tentatively, is
that the way to produce cancer with alphas is to irradiate
as many cells as possible with a very low interaction rate,
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453
a risk proportional to R2 t3. It would apply approximately
in the low dose rate range up to a few hundred rads cumula-
tive dose. As soon as you get above that dose -- as soon as
you start hitting each chromosome two or three times per
cell generation -- then you have got to put in other factors.
You will begin to waste the radiation, and you will be
killing the mutated cells. Therefore, from that point on,
it takes more and more activity to do the job. Once we get
high enough in specific activity, you will start the process
all over again by a different mechanism --by ablation and
dissolution of extremely hot particles which is a function
of particle surface area and specific activity.
Dr. Garner: Just to come back to the ablation business,
you mentioned this that the plutonium deposit on soil would
greatly assume smaller and smaller size, but at the same
time you have got the compensating factor that this stuff is
moving down in the soil in a sort of profile. I think this
is a proven fact that it does move down.
Dr. Martell: There is something very interesting about
that. The only old profile of plutonium is that down at the
Trinity site, the site of the first nuclear explosion, in
New Mexico. There one finds that there is a higher rate of
vertical transport downward in the soil for the higher
specific activity plutonium-238. Plutonium-238 migrates
more rapidly downward than plutonium-239, but it also shows
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454
a remarkable increased uptake in the biosphere. It is
highly enriched in vegetation and in small animals in this
region. So, the very properties of higher specific activity
that make it more mobile in soils also makes it more mobile
and more readily taken up into the biosphere and man.
Therefore, I am not reassured by an aging process which
makes it more available for biological uptake at the same
time as it tends to weather and degrade it. You have to
look at all aspects of these limited observations to appre-
ciate the full implications of weathering.
Dr. Morgan: Dr. Martell, I was fascinated by your
presentation and your theories. You refer to the theories,
explanations of Philip Burch, Robin Hall, and others, namely
that prolongation of the alpha radiation of the chromosomes
or protracted radiation is greater than the high dose, this
you realize, of course, is borne out by the rather recent
observations on radium-224 studies by Mays at Salt Lake City
and Spiess, and others, namely that with the protraction of
the dose you get a higher carcinogenesis.
Dr. Martell: Yes.
Dr. Morgan: I feel also that your point is well taken
that we should look at other indices besides lung cancers,
bone tumors, in the case of plutonium, for example, look at
things like arteriosclerosis. You realize, course, for many
years it was felt that Thoratrast was a completely safe
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455
material to use as a contrast medium. Thorium is very much
like plutonium, and it was only 30 to 50 years later that
these cases of epatic tumors began to show up, so at these
low levels of exposure it may be that we are not even focus-
ing on the primary target. I feel that a hypothesis, how-
ever, is only as good as its experimental evaluation, and
you mentioned the case of the spallation of plutonium par-
ticles and using this as a possible explanation for the
greater risk of plutonium-238 as against plutonium-239. You
also mentioned that the risk seems to vary with R2 t3. I
wonder if these same relationships can be checked with your
studies on Polonium-210 and the cigarette smokers. Is that
a possibility?
Dr. Martell: Well, it will take a bigger effort than I
have at my disposal. My research group working on this
problem is one full-time experimental assistant, one-half-
time student assistant, and the occasional assistance of one
professional colleague. There are only a limited number of
things that we can do. What we are doing now is working
with Dr. Radford on lung tissue and lymph node tissue speci-
mens from deceased smokers and nonsmokers. I am discussing
possible collaboration with two different groups that are
concerned with the nature of arteriosclerosis plaques and
their alpha activity concentrations. We are doing a few
preliminary tissue measurements of main aorta tissue at the
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456
present time. We are also taking some large tissue speci-
mens from the lung and other sites, and are separating the
insoluble and soluble components and measuring lead-210 and
polonium-210 in each fraction, so that we can directly get
at the kind of specific activity distribution in advance of
being able to do a separation of particular segments of the
tissue that have higher concentrations.
Dr. Morgan: Do you get spallation from these parts?
Dr. Martell: I mentioned spallation work only because
it is a very nice analysis to explain the observed rapid
migration and the apparent higher dissolution rate for the
hotter particles. It was done by a Dr. Robert Fleischer, an
outstanding man from the General Electric Research Laboratory
in Schenectady who has done a lot of work on the development
of fission track techniques of analysis of transuranium
elements and isotopes. Simple experiments could demonstrate
whether this hypothesis of his is correct or not. But, you
see, even if it is simply a rapid dissolution of high speci-
fic activity particles as a consequence of radiolysis of
fluids and the chemical reactivity of free radicals formed --
even if that is the case -- then we know from experience
that this dissolved activity will, in course of its migra-
tion away from the hot particle, coagulate, leading to the
formation of small focal points of activity. There are a
number of studies of inhaled, dissolved soluble compounds of
plutonium which have demonstrated the formation of these
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457
focal points. If you start with dissolved activity, you get
particles. If you start with particles, you degrade them.
So, we are almost always dealing with small focal points of
plutonium, no matter whether you start with dissolved activity
or with particles. And the specific activity and surface
area will determine to what extent the hot particles degrade
into smaller materials. If you have dissolved materials,
you are still going to wind up with concentrated focal
points of low activity, but not a uniform distribution. You
essentially never get a uniform distribution for plutonium,
no matter what compound you start with.
Chairman Mills: If there are no more questions, I
would like to declare a five-minute recess.
(Whereupon, a short recess was taken.)
Chairman Mills: If we could, we would like to move
along. We are determined to get this hearing completed
today or tonight, therefore we appreciate the patience of a
lot of speakers staying with us until we get through with
the thing.
The next speaker is Mr. J. Fowler of the Colorado
Organic Growers and Marketers Association. Is Mr. Fowler in
the audience?
(No response.)
Chairman Mills: Perhaps we could go to the next speaker
and come back to Mr. Fowler.
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4S 8
Based on available public information, ] and others at
UNC have determined the total quantity of plutonium-239 and
americium-241 that have been spread over the Rocky Flats
area during the last 15 years. I might say this was
extremely difficult, since the figures published were in
different units and made a difference, and we do not know
now whether the units that I am going to give you include
the americium or they do not. But, we believe that cer-
tainly if we just take the information that I have and it is
quite extensive, it does appear that somewhere between 13
1/2 and 16 1/2 curies of plutonium have been spread over the
Rocky Flats area, and perhaps up to 3 1/2 curies of
americium-241. As far as I know, you could either subtract
the amount of americium or you could add it.
Also, we would like to support the Colorado Public
Health 239 toxicity figure of .2 of a DPM per gram instead
of the higher figure of 2 DPM, because we beLive that the
Academy of Science information of two years ago which I have
in here as a reference indicates that the lower figure would
be a much better figure.
It is interesting to note that Colorado is one of the
few states that does have a toxicity of limit on land areas,
and if I am correct, neither EPA nor AEC has the toxicity
requirements for areas, and neither EPA, AEC, CPH have
toxicity requirements for americium-241, which is certainly
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459
I find that it is much easier to obtain information
concerning the hazards of radiation than it is to find out
that a meeting such as this is being held. We citizens
certainly were without early alert, but I hope that the
policy makers are not so slow when it comes to stopping this
radiation hazard.
I am a natural hygienist, and as one, know that our
health is maintained with sunshine, rest, fresh air, and
pure water, as well as unpoisoned food, and know that our
health will be upset and we will get cancer and leukemia
from radioactive debris in our soils, our food, and our
water. I do not want these plutonium particles in ray lungs,
and I do not want them on my apples.
Dr. Virginia Vetrano, a natural hygienist practicioner
from San Antonio, Texas, has been compiling information
about the hazards of radiation since 1954. Her findings
indicate that younger people, those born since 1942, have
more heart deformities which cause heart murmurs than those
born before the war. Now this could likely be one of the
effects of ionizing rays. It may not be 100 percent con-
clusive of radiation effects, but the timing indicates a
good possibility. We have got considerable reason for
concern in the fact that leukemia and cancer have been
increasing so fast that one in every three or four persons
is now destined to contact cancer. We doubt that we could
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460
afford to let any extra contaminants that might cause these
to increase to be released. Now, Charlevioux County, Michigan,
has an infant mortality rate 49 percent higher than the
State, and the immature infant rate is 18 percent higher,
leukemia 400 percent higher, cancer deaths 15 percent more,
birth defects 230 percent higher than the State. Charlevioux
County is the site of the Big Rock Point Nuclear Power
Plant.
Dr. Linuis Pauling, a Nobel Prize recipient, states
that the only safe level of strontium 90 in the bones of
children is zero. He also tells us that radiologists have a
five-year shorter life expectancy than physicians. Now,
Time Magazine in 1962 carried a news summary showing that
constant exposure to radium was causing a higher rate of
deformities among radiologists than the general public.
Schubert and Lapp explains how rapidly dividing cells
of embryo in young children are more sensitive to all kinds
of radiation and are very easily damaged. An older person
receiving a dose of radiation has a better chance of dying
before he develops cancer, but there is more than ample
chance that infants will develop cancer early in life.
There is already as much or more background radiation
than we stand. This, of course, has been increased by x-
ray, T.V., and past nuclear tests.
Dr. Phillip Bursch (Director of Environmental Health
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461
Research in Leeds, England) finds that four of every 1-
thousand cases of cancer is due to natural radiation.
The Journal of American Health carried an article
reporting that there are 50 percent more deformities in the
areas of New York where there is a higher background of
radiation.
Dr. Herman Muller, a scientist who over 40 years ago
experimented with the fruit fly, came to the conclusion that
there is no dose so small that it does not cause mutations.
Experiments with animals were carried on at the time of
the Manhattan Project. They found that one group of animals,
given so small a dose of x-ray as to think there was no
concern, showed no effects at first but later generations
did begin showing genetic damage and this lasted as long as
21 to 23 generations.
George Weil, author of "Nuclear Energy Promises,"
states that there is no way to completely contain elements
from an operating power plant, and that release of these
into the environment is routine, and that they rapidly pass
through the food chain causing leukemia, cancer, and genetic
damage which may show up years or generations later.
Drs. Golfman and Tamplin, of Lawrence Radiation Labora-
tory in California and the authors of "Poisoned Power,"
state that there is no way that nuclear power can be generated
without also generating radioactive poisons. Once these are
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462
released into the environment...and they believe that this
is likely to occur...the pollution of the environment will
be irreversible and will remain so for centuries.
Shubert and Lapp state that no cell fully recovers from
a dose of radiation. While cells may appear to recover,
there is irreversible damage to the genes and chromosomes.
Dr. Grubbe, who was the first to use x-ray in attempting
to treat cancer, died a painful death from radiation-produced
cancer which caused his arm, some of his fingers, and chin
to be eaten away. He was concerned about his plight and
others that might be exposed, and he emphatically proclaimed
that all ionizing rays are dangerous.
Now, test analysis for testing animals is not altogether
conclusive, for Shubert and Lapp found that man is more
susceptible to ionizing rays than most animals. It takes
twice as much to be a lethal dose for a rat as for a man,
and a cockroach can stand a lot more than either one of us.
Now, since we do not drop dead from the effects of
these rays, the AEG, it seems, have been bidding on the fact
that we, when we have problems with cancer, leukemia, and
deformities, would not know where our problems came from.
We will not be able to trace them.
Roswell Park Memorial Institute, this seems to be a
part of the Department of Health of New York, state there
are hazards of a reactor blowup that would make headlines,
-------
but the invisible genetic damage done during routine
operations is of more serious risk and cumulative promises
show that painful death for children would result, and many
of these are still unborn. Often visible effects will show
up during the life of the person exposed. They conclude
that a single x-ray plate seemed to be of little risk to an
individual, but invisible damage, that to the genes, and
materials of cells, this damage can show up in the one who
has been exposed to this x-ray, his children, and his
grandchildren, and follow on from there.
They also found that x-ray during pregnancy strikingly
increases the child's allergies and certain diseases. This
increase was 5-hundred percent. They found that supposed
safe levels of x-ray radiation dosages resulted in children
being vulnerable to leukemia and other diseases. Many of
these children would not live long enough to get leukemia.
See, that might be one of their advantages.
Alex Carrol, Nobel Prize winner who wrote "Man the
Unknown," states that man knows quite a bit about science
and he knows quite a bit about medicine. But what he does
not know is an awful lot more. I think where us citizens
are really concerned is that there is considerable known
damages, there is considerable known hazard, but there might
be a lot more than we yet know about. Now, since the insur-
ance companies are free of the hazard, the Government will
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464
not cover us. But, these people are not going to protect
us. Who is? Norway and Sweden do not seem to want nuclear
power plants. If they do not want them since they do not
have vested interests there, I do not think we might want
them here. I am concerned for my fellow man, for the unborn
children, and I hope that the policy makers will have the
courage and the conscience to protect us by setting a zero
standard for radiation above what we normally have. It will
be too late if it requires a disaster to stop this menace.
Now, I have brought a paper here, and since we thought
that the AEG was protecting us, it states -- I would like to
read what the AEC has to say, while we were under this
assumption. This is May 4, 1974:
"The Atomic Energy Commission announced that a
cloud of radioactive tritium accidentally dis-
charged from its Savannah River plant was drifting
across South Carolina. At 200 feet, the cloud
will dissipate in "a matter of days.' 'The hazard
comes through breathing or ingestion,' said AEC's
spokesman."
"On March 15, another 2,500 gallons of highly-
radioactive fluid leaked from storage tanks in
Hanford, Washington, making the total amount
leaked since 1958 approximately half a million
gallons. It is the seventeenth such leak re-
ported, this one was spotted with new atomic
detection equipment installed last year. The
AEC's representative said the liquid is expected
to be absorbed in soil before it reaches the
water table, 210 feet down."
"In February 1973, the AEC's former top secruity
officer, William T. Riley, was sentenced to three
years' probation. --
Chairman Mills: Mr. Pelton, I am really not sure that
is relevant to our purposes to getting information on stand-
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465
ards, I think. So, could you confine it to those remarks?
Mr. Pelton: I guess I was getting around to the fact
that I was trying to conclude more that we probably have not
had very much protection from the AEC. As concerned citi-
zens, we would like some more, and we hope we can get it
from whoever the policy makers are now.
Chairman Mills: Thank you very much. I had on my
agenda your name was Felton, but I assume it is Pelton, "P"
as in plutonium?
Mr. Pelton: "P" as in plutonium.
Chairman Mills: Could you give us your full address?
Mr. Pelton: 3175 South Clarkson.
Chairman Mills: Are there any questions?
(No respone.)
Chairman Mills: If not, Mr. Fowler?
(No. response.)
Chairman Mills: Well, I will assume that he did not
last.
Is Dr. Sorteberg here?
(No response.)
Chairman Mills: Is Dr. Anders from the University of
Northern Colorado here?
(Whereupon, Dr. Anders approached the podium.)
Chairman Mills: Dr. Anders, will you give us your full
address?
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Dr. Anders: My address is 1525 - 15th Avenue, Greeley,
Colorado.
In Greeley, we are preparing for the advent of the
Saint Vrain Nuclear Reactor, and as you know, there will be
two more reactors that are scheduled to go into this area.
So, we are going to be having our hands full.
What we have done, though, in the past three and a half
years is take a tremendous number of samples up there. We
have taken air samples every day. We have taken water
samples all over the area, and we have taken soil samples.
I wish today that I could tell you that we could prove once
and for all that plutonium oxide has been found in the
samples, but I cannot at this present time. I hoped that I
would have that information for you today, but I do want to
point out that I believe we will show plutonium oxide getting
as far as Greeley, and perhaps from Rocky Flats.
Dr. First: How far away is that?
Dr. Anders: That is about 60 miles directly --
Dr. First: Which direction?
Dr. Anders: Northeast approximately. Now the winds do
not blow that way very often, but we are getting increased
alpha counts, and we do not know whether it is plutonium or
americium or what it is at the present time. The fact is we
asked for assistance in this area and were turned down by
the Public Health Department of the State.
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467
I am one of the prime litigants that have been the
litigant against EPA, and so far I have been quite success-
ful. One thing I want to mention though is that I think EPA
is absolutely required for the people of Colorado. We exist
in the highest altitude where we have, as you know, the
highest number of millirems, around 240 coming from natural
resources. We have nine millirems that come to us from
fallout, and then we get on an average of around 100 milli-
rems from our doctor and dentist, and according to the
Academy of Science, we do not have many millirems to go. So
Lord knows, I do not know why we have so many radioactive
designs on us up here. It seems that everyone wants to put
something radioactive here, including the latest I heard is
a possibility of putting a processing plant north of Greeley.
So, we have got to try to help the EPA to do its job.
One of the ways that we could be helped, I believe, is
to help us communicate with one another in this field. I
give you the following example: I think I was the first to
receive the isopleths of Rocky Flats information especially
on plutonium. I got them early in 1971, and I tried to get
the information out, and have been unable to. In other
words, I was unable to get it through the local newspapers
and of course they have their reasons for it. I am hoping
that some day we might find a way of getting information
like this to the people who would be interested in it.
-------
4S8
Based on available public information, I and others at
UNC have determined the total quantity of plutonium-239 and
americium-241 that have been spread over the Rocky Flats
area during the last 15 years. I might say this was
extremely difficult, since the figures published were in
different units and made a difference, and we do not know
now whether the units that I am going to give you include
the americium or they do not. But, we believe that cer-
tainly if we just take the information that I have and it is
quite extensive, it does appear that somewhere between 13
1/2 and 16 1/2 curies of plutonium have been spread over the
Rocky Flats area, and perhaps up to 3 1/2 curies of
americium-241. As far as I know, you could either subtract
the amount of americium or you could add it.
Also, we would like to support the Colorado Public
Health 239 toxicity figure of .2 of a DPM per gram instead
of the higher figure of 2 DPM, because we belive that the
Academy of Science information of two years ago which I have
in here as a reference indicates that the lower figure would
be a much better figure.
It is interesting to note that Colorado is one of the
few states that does have a toxicity of limit on land areas,
and if I am correct, neither EPA nor AEC has the toxicity
requirements for areas, and neither EPA, AEC, CPH have
toxicity requirements for americium-241, which is certainly
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469
as toxic as plutonium-239.
During the last several years, as I say, we have had
continuous air sampling being taken in the Greeley area, and
I have been present when the measurements were made. Many
times the counters gave readings which were in excess of
background count. As I have mentioned before, we are not
sure where it is coming from, but we suspect that it is
coming from down here. Dozens of examples, not dozens
really, hundreds of samples since we have been doing it for
three and a half years every day without fail await the EPA
or state confirmation of our results.
Is has been established that the particle size of
plutonium particles is a very important variable in establish-
ing the toxicity to humans, and it appears to us then that
the longer plutonium oxide particles are left alone, the
more toxic it will become. Therefore, it does appear that
this is so; we have to get rid of what is out there or
perhaps the transferring of Rocky Flats. Therefore, it is
suggested that EPA include particle size in its toxicity
standards.
Finally, I have included a copy of the recent history
of Rocky Flats, a document I made for the Rocky Flats Action
Committee. I hope you will find it useful, because it gives
a complete history of the Rocky Flats area. I have many
questions I would like to ask, but I have put them in a form
here so you might be able to answer them for me.
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470
RECENT HISTORY OF ROCKY PUTS BY FRANK w, ANDERS 24082
(All information taken from Rocky Mtn. News or Denver Post)
10/10/52
2/7/69
5/5/69
9/29/71
1/4/72
2/9/72
3/10/72
10/19/72
"
10/25/72
10/26/72
4/26/73
/ 9/7/73
10/10/73
1 10/10/73
1/10/16/73
v 9/20/73
Rocky Flats sited
Rocky Flats to get $113 million for new plutonium recovery facility
and 4, 640 acre buffer.
Rocky Flats Fire- AEC claims radioactivity escaping "minimal"
400 workders exposed "up to 17 times per mis sable levels".
AEC announces for 1st 6 months of 71 contamination of Rocky Flats
is within limits.
Rocky Flats to get $130 million to avoid repetition of 1969 fire.
AEC finds 18 Dow employees were subjected to plutonium leak.
Dr. Martell disagrees with Colo. Health Dept. and AEC measurements
of plutonium amounts around Rocky Flats.
Dr. Martell finds 5 curies plutonium east of plant boundary. Dow
claims this from oil drums spillage, not from 1969 fire.
Dow and AEC claim plutonium in soil is not dangerous and state
there are no limits on ground bearing radioactive wastes.
Dow summarizes for Jan. -June 1972: 7% of guidelines in air for
plutonium, 1% for uranium, 6% for beryllium. In water 1% Pu,
in drinking water .04% Pu. Be (yr)=4. 3 grams
-17 air samples at plant site exceeded annual average.allowance of
Radioactivity. Average Pu concentrations were less than 2% of
guidelines in air and water. CHD, EPA agree with Rocky Flats.
Toxicity of Beryllium is at less than 2% of normal. During 1972
releases of long-lived alpha particles per year equalled 58 million
pc+8.7 million pc from uranium enrichment. Community ai* samples
Pu-24% of air standard. At plant <10% Pu standard. 2-4 miles from
plant 2% standard air plutonium. For water at plantsite
-------
471
9/19/73 Discharge into Walnut Creek (tritium) ~1200 pc, I average
but in July and August ^23,000 pc/1 . Dow expects new plant
in 1976 to solve problems. Walnut Creek supplies 2% of
Broomf ield's drinking water.
9/25/73 First announcement by State Health officals:
/vBldg. 771 102,440 pc/1
North Plant 33,000 pc/1
Broomf 1e1d 23,000 pc/1 (water supply)'
9/25/73 Broomfield City Council requested AEC to divert Walnut Creek
from Reservoir. Aghast at time of discovery and notification
at Governor's press conference- time lapse: April 24 to Sep. 14.
8/7/73 AEC says soil above RF burial grounds has never been sampled
beforel
Burials at RF were
1.952-1968 ash from burning % Ib. depleted uranium
1954-1962 metal drums filled with Uranium scrap metal
(thought it had been removed)
1954-1968 Number of empty crushed drums which had contained
enriched U.
1968-1972 20-55 gal. drums of sewage sludge of U
1969- 320 tons cf asphalt ?nd contaminated soil from
May, 19G9 fire bur>ed under bldg. 881!
1969- 6 curies Pu leaked onto ground from corroded
drums 'or? east side of plant) Pu particles are
94>,OM <,v ft.
10/10/73
12/8/71
1961-1965 4 Ibs. of depleted U waste burned.
Broomfield City Council went to Court to prevent AEC from
discharging wastes.
Gov. Love: wants RF located elsewhere.
-------
6/12/73 AEC to begin $113 million building 1n Oct.'73.Pu-$18,000/#
Low level wastes being shipped to Arco Kdaho (only 75X
reduction is forseen). New facility won't pollute: "be
so low as to be of no significance to environment.")
10/18/73 Sr90 and other radioactive Isotopes "of a classified nature*
wer were found in small amounts 1n Walnut Creek.
12/21/73 New contract to run Rocky Flats will be let next month.
AEC announces tritium was released from stacks 1n 1968 and
"occasional" releases since 1970. 500-2000 curies tritium
were released from stack at 779-A (From a Livermore
shipment) Sr90 was found and will be monitored from now on..
3/21/72
12/16/73
9/28/73
11/8/73
Of 18 cancer deaths reported by RF, brain cancer 1s leading
type of cancer with 4 male deaths followed by lund cancer
with male deaths.
f RF radiation Incidents:
employees, In glove box explosion, $31,000 cost
employee changing filter
processing Pu
Nitric add and Pu spillage
Leakage 1n Pu line $8,364 damage
employee explosion glove box$56,500 damage
Leakagi in Pu'llne' $7,557 damage
Pu explosion $17,057 damage, up to
7 times lung burden
Pu explosion $23,253 damage
Torn glove In glovebox $1,306 damage,
Up to 2% times lung burden
Glove box (no shielding)
Am241 poisoning (excessive handling)
Pu radiation.
Pu radiatloi.
Pu radiation. $10,246 damage.
Pu fire (full burden)
Pu fire (4X burden)
Pu fire (16X burden)
GTo'.'.i box r-j^ttra (4X full burner.)
Short hi!
6/14/57
2/4/58
6/1/62
4/23/63
6/20/60
6/12/64
5/6/65
10/15/65
11/9/6S
3/19/65
3/30/67
3/30/67
6/30/67
9/30/67
9/30/67
10/14/68
3/23/69
8/22/71
2'8'7?
.tor,
2
1 i
3
1 i
3
10
12
1
3
1
3
6
..
1
1
1
1
Tritium doesn't stay 1n body very long % that swallowed passes
on 1n 12 days. 3,000,000 pIcocuHes of Pu/I1ter during peak
days now at Is 3,000 pc/1 (1,200 pc/1 natural level)
The current International safety standard for maximum average
radioactive (tritium) content 1s 1,000,000 pc/1 15
Drinking HgO for 1 yr at 10,000 pc/1 is equivalent to
2 mrem/yr compared to complete dental x-ray of 5000 mrem.
EPA to recommend new tritium 11*1 It: 30,000 pc/1. In April
CHO found 23,000 pc/1 1n Great Western Reservoir (water supply
for most of Brcomfleld residents'/ State standards are
1,000,000 pc/1! No specifications are assigned to actlnlde
series.
Public health questions can't be resolved until 1981 (Dr. Rowe
EPA)
AEC to divert Rocky Mountain wastes: proposal to quit putting
250,000 gallons liquid Into Broomf'eld's water supply (60%
industrial wasta, 40% sewage)
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FWA 24082
Page 3
473
'9/16/74
9/7/74
9/22/74
9/29/74
J:
2/15/73
10/26/73
12/12/73
9/30/73
7/8/73
9/30/73
9/20/73
10/17/73
10/18/73
Since 1953, according to AEC .'eport of Rocky Flats 271 fires,
410 contamination cases, 75,000 drums of traces of plutonium.
3700 people work there, ^'iant cost $250 so far plus $45 -
million for 1969 fire pits $20 million for buffer zone. A
new plant would cost $500 million.
1 curie tritium released Into air, (h max. allowed) Rain caused
pools of 1/20 max believed to be from 1973 Incident.
Truck loses RF containers, 16X24, empty, returned by passing
material.
AEC: tritium release w?.; traced to RF (not from outside AEC
Agency).
3/21/72 According to Ed Martell: Pu239 1000 times/normal at Eastern
boundary to 10 times 43/4 mi. away (1 mile from Aryada).
Normal Pu239--*l£00-pc/m2 -(from^faHout). At eastern
He says standards exist for
Pu in air and water but not in vegetation or on ground. Dow
claims wind and erosion can concentrate the Pu. Martell says
Pu241 is not reported tho it decays into Am241. Also Pu239
toxicity in rats i> same for man.
Hearing sontinue on Pu soil standards. Proposal 1+ disintegrati
rate is greater than .2/minute/qm of dry soil then land is
urifit for residential use. AEC Is against soil pollution
standards. Hanes, genl manager of RF, claims only 1 teaspoon
of Pu is dispersed over 50 sq miles: "There is less radiation
leaving our stacks and sewage plant than is coming into plant
by satural source."
AEC admits error in tritium handling, but not in Pu wastes.
AEC invites bids for RF- before 1975 (July) Fire cost $50
million- most co$-stly industrial fire in history. Dow admits
Pu poisoning of area east of plant.
Or. Sangoy Dasgupta was threatened with deportation because
of AEC pressure for releasing info on chromosome damage on
Dow workers (34).
Uranium-enrichment plant (@$2 billion) eyed for Rocky Mountains.
Tritium was traced to Bldg. 779. Chromosome changes were found
in 34 workers at Dow by Dr. William Brandom. He said Dow
workers' urine abnormally high in tritium.
Dow claims no tritium leakage from them: tritium passes thru
body in less than 600 days and a non-Broomfield resident had
3600 pc/1 of tritium in his urine because he wore a tritium
painted watch. Broomfield's residents were harried and angry.
AEC claims discharges of tritium, Pu, Am into water supply.
Of 3 Denver suburbs are well below permissable standards
(Broomfield, Westminster, Thprnton)
Possible aeration of sediments in bottom of retention ponds
could account for Pu increase in Walnut Creek. Construction
in this area may have been responsible. The retention ponds
were drained if Pu were soluble it would not have been
removed by water treatment. It would enter into drinking
pond - 285 pc/1 were found 10/2/72
-------
IV
*• . *
12/21/73
12/21/73
12/21/73
1/16/74
2/5/74
'. 2/5/74
2/7/74
A 24082 Page 2
. 9/26/73 Dow admits no tools to measure tritium. No beta emitters is
measured.^ Figures from CHD: 33,000 picocuries tritium per liter,
(natural background^ 1200 picocuries/I). Dow estimates 70 curies of
tritium have leaked into environment (1 gram tritium=10,000 curies)
9/26/73 At piutonium recovery facility drain- CHD found 102,440 picocuries
per liter. US.GS is analyzing underground water at plant site. Dow
doesn't know source.
^ ir piro-irr/ii'd water supolv not dangerous.
* * •"* Jf •*" T" *
CDH restmautle for .v.unuoring Rocky i'l^ts foun* tht t'**.•• ium releases
described below. Wastes were not monitored by Rocky Flats before they
were discharged into Walnut Creek.
Occasional releases of tritium have occurred at Rocky Flats since 1970
without a report being made to anyone.
AEC charged Dow failed to report accidental releases of radioactive
materials in 1968- 600 Curies of tritium thru smoke stacks and greater
than 600 curies of tritium thru exhaust sytem into Broomfield reservoir.
' AEC confirms that 'dangerous levels' of tritium were found in Great
Western Reservoir. AEC will keep SHD apprised of all released
substances. Nitrate levels rose to 8 times acceptable levels.
No Sr89>90 found by AEC, EPA finds 4pe of Pu per gram of sediment
vs. . 6pc/g earlier. No standards for Sr! Rocky Flats will not
discharge any more Pu.
AEC finds 18. 6 grams of Pu239 leaked into 2.85 acres of ground from
buried drums of Pu wastes which had rusted. AEC said there are
17 other areas where wastes are buried- only 60 ft. from this area.
is a 3 acre blanket of asphalt covering 86 grams of Pu spilled in '68.J
124,000 f# has 7 grams or 3 curies of Plutonium (24,000 yr. half life).
Previous AEC reports show wind blowing plutnnium contaminated oil
into this area (security fence) between 1958-67. Vanderboof shown
17 other contaminated areas. In SE sector 60 yds3 of Pu contaminated
soil was buried . Non-radioactive lithium buried in 1956-70 period.
'No health hazard.' In oil-drum storage field: 3,572 drums of Pu
@ l,2£4 drums of Uranium contaminated oil buried.
5/15/74 AEC finds 'no health problem1 from Pu239 found in core samples
driven into mud at reservoir area.
5/16/74 AEC finds radioactively contaminated mud in Miamisburg, CH and
Hanford, Washington- newly formed teams search for cor.tamination-
all a result of Rocky Flats debacle.
6/1/74 Because of contaminated Miamisburg facilities, Monsanto withdraws
from Rocky Flats bidding.
^i 7/21/74 GAO tells AEC to warn pregnant women working at Rocky Flats and
other plants of dangers to fetus arising from AEC standard at . 5 rem.
GAO says this figure is 10 times higher than Nat. Acad, of Science
recommendation
V 7/25/74 By Jan. 1975 a l/2 to I mile buffer zone will be bought for $11. 6 million.
This buffer s:one will extend around Rocky Flats.
8/1/74 EPA accuacu AEC and Dow of negligence and poor attitude in checking
for tritium after it was found by CHD and confirmed by EPA,,
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475
RECOMMENDATIONS CONCERNING ROCKY FLATS (FWA 11/74)
1. Plutonium concentrations over land areas have no specifications
whatsoever. Lethal limits must be sought, possibly 10% greater than
fallout values.
2. The time between finding radioactive pollution and the time of
reporting must be reduced from 3 years (nukes), 6 months (Rocky Flats)
to days or hours.
3. Public permission must be given to Rocky Flats to check Us
radiation pollution. Also, the State Health Department must allow
unbiased groups to analyze plant pollution.
4. Recriminations from AEC or others must be prevented whenever public
Information 1s Involved. AEC must be severly limited 1n what it calls
"security matters."
5. Investigations Into finding other areas for Rocky Flats must
begin now- before Nort West Denver 1s engulfed .1n pollution.
6. All radioactive materials and all chemicals produced by Rocky
Flats must be analyzed. Only .1 of 11 Is being analyzed for now on
a continuous basis. To do this, State Health must be given more money
for more qualified people and more exotic testing equipment.
7. The State Department of Health must not be given the power to veto
other qualified groups from analyzing radioactive pollution.
8. US Government, State Government and private groups have specifications
on radioactive pollutants which vary by as much as 6 orders of magnitude.
These differences must be brought Into line- pressing for the least
toxic specification.
9. AEC must be prevented from buying more and more property, to hide
Its pollution. Putting land permanently "off limits" is the ultimate
sin.
10. AEC must publish for all to see Its Isppleths on all material
pollutants out to 100 miles.
11. Everyone must fight for the right to get adverse criticism of
AEC into print. It 1s ridiculous to be told by the editors that
they are afraid of being sued by AEC or PSC or any other powerful
group.
-------
E IRONMENTAL PROTECTION AGE! f
JAN 2 4 1975
Dr. Prank Anders
University of Northern Colorado
Greeley, Colorado 80631
Dear Dr. Anders:
I am responding to the five questions you submitted to me at the
recent Public Hearing in Denver on plutoniutn.
Question 1; "Do we have for Colorado todcry a capability of
detecting and evaluating transuranium nuclides in either EPA, AEC,
CIO) or other facilities?"
Respouae; Yea, EPA, AEC, and the Colorado Department of Health
have the capability of making measurements of the transuranic
nuclides, especially for plutonium. The detection of americium,
curium, and some of the other radiomiclides, however, may involve
considerable analytical capabilities. I believe that the testimony
given by the Atozoic Energy Comaission, which was referred to by
Dr. Gurr during the hearings, should be helpful to you in this
regard.
(Question 2; "Has anyone E'.ade a calculation of the cost of
reraoving Rocky Flats elsewhere?"
Response: Yes, there have been estimates raade of the roplaceiaent
cost for Rocky Flats. In 1970, this cost was estimated as $500 million
to $750 million. These estimates were civen in the AEC's response in
the environmental statement on the plutoniura recovery facility, Rocky
Flats plant. (WASII-1507, January 1972.)
Question 3: "Has anyone wade an analysis of birth defects in the
Rocky Flats area?"
-------
477
Response; No. It is ay opinion that it would be quite difficult,
if not inposoible, to determine any changes in birth defects associated
with radiation exposure in the Rocky Flats area, because the rather low
levels of potential exposure involved and the size of the population
group are inadequate to provide a conclusion as to a causal relation-
ship. I should call to your attention that the type of defects you
are raising a question about requires either deposition of radioactive
material in genetic tissues or the transoittal of these materials
across the placenta during prenatal development. *For your information,
I am enclosing a copy of the 1972 NAS report entitled, "The Effects on
Populations of Exposure to Low Levels of Ionizing Radiation," which I
believe will be informative in this matter.
Question 4; "Has anyone noticed that because of our altitude and
position in the mountains that this should be one of the last places
in the U.S. where proliferation of nuclides should be allowed. After
we receive our 250 mr from natural sourcea and fallout and we add
100 rar/yr from average dental and medical x-rays — Can we stand
multiple increases of 5 mr from this and that source?"
Response; This question does not lead to a direct yes or no
answer. You are aware, of course, that there is a geographical varia-
tion in natural background radiation, as well as a variation in the
anount of radiation received from its use in the healing arts. We
cannot, under the present assumptions of a linear, nonthreshold dose-
effect relationship, determine a "cafe" acceptable level of radiation.
Therefore, the additional exposures, which individuals or populations
experience, ir.ust take into consideration the health impact, the
economics to control that iapact, and a judgment as to the benefit of
the activity. Such an evaluation is, as you might gather, quite
complex. Keep in wind, however, that with an assumption of a linear,
nonthreshold dose-effect relationship, the incremental risk increase
with increase in exposure io independent of prior exposure.
Quastion 5; "lias anyone looked at the iuoplcths of Sr-90, Ce-144,
Cs-137 around Rocky Flats?"
Response; Yes. The DOW Chemical Company and the Colorado
Department of Health conduct routine environmental surveillance programs
in the vicinity of Rocky Flats, which Include the sampling and analysis
of media for the radionuclldcs which are most llkaly to be released
from the Rocky Flats plant. The Health and'Safety Laboratory of the
AEC has also perforned surveys In this area. These data are reported
-------
478
U3 individual sanple measureraenta and not as radionuclide isopleths.
Although Sr-90 is not a routine analysis in either of these programs,
it has on several occasions been the object of special environmental
studies. The AEC (?^RDA) has done extensive aerial surveys by use of
their Aerial Radiological Measurement System aircraft. This survey
niapped the Rocky Flats area and would have detected very low levels
of these radionuclides«
Sincerely yours,
Director
Criteria & Standards Division (AW-560)
Enclosure
cc; Paul Sr.;ith, Rccion VIII
A.J. llazle, CDH
bcc: Dr. Augustine
Mr. Harv/ard
llr. VJcaver
Dr. Hurley
-------
479
Chairman Mills: Thank you, Doctor. Are there any
questions?
(No. response.)
Chairman Mills: If there are no questions, Mr. Dwight
Filley, from the Colorado Open Space Council, Inc.
(No response.)
Chairman Mills: Mr. Albert Nunez of Environmental
Action of Colorado. I apologize if I did not pronounce your
name correctly.
Mr. Nunez: You did quite well. I hope you can do as
well by setting some very, very, very low standards.
Chairman Mills: Would you give us your address?
Mr. Nunez: Environmental Action of Colorado is
affiliated with the University of Colorado at Denver, 1100
14th Street, Denver, Colorado, 80202.
The comments that I have are just very brief. I would
like to say that there is probably nothing that I am going
to add technically speaking that has not already been very
more than adequately covered by expert witnesses that pre-
ceded myself.
I would just like to point out a few things from my own
background which has been in planning, urban planning in the
Denver Regional Area, and that I am very concerned about the
area surrounding Rocky Flats, not only Rocky Flats, but
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480
other nuclear facilities around the country, the public
awareness of these facilities, and the potential hazard
involved with them. The urbanization of these areas within
a 50 or 100 mile radius I think is considered a potential
hazard zone in the event of a nuclear accident.
I do not know exactly how you are going to take into
account possibilities for an accident when setting your
standards, but one suggestion that I would like to enter
into the record and that would be that as monitoring sta-
tions are set up around these facilities, particularly the
ones close to urban areas, but even those not close to urban
areas -- I will touch upon that a little further down the
line -- that a posting of the hazard zones, if you will, the
isopleth showing the different concentration levels of these
radionuclides be acturally posted by the highways so that
people will become more and more aware, just as the Surgeon
General has posted a caution label on the side of cigarettes.
A similar type action if, for no other reason but just to
increase public awareness and to start people to become more
and more aware of the potential hazards involved. I do not
know if you can work that into your standards or not, but I
would just like it to be included in the record.
I would also like to ask what knowns do you know about --
what are the knowns about plutonium, and what are the unknowns
compartively speaking? How much is there on this spaceship?
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481
How much plutonium is there? Where is it all? These kind
of questions are necessary for you to ask, considering the
extreme toxicity of this particular element, and of course
the other transuranium elements that are also being con-
sidered.
My own personal feeling is that the hazards involved
are not knowns at the present time judging from what I have
heard thus far in the testimony, and that I really do not
see how you are going to be able to set any standards what-
soever until further research is done; and that for all
intent and purposes, we have kind of opened a Pandora's box.
We have already produced certain amounts of plutonium, but
have no real assurances of how much, what is a safe level
for human or other animal consumption.
Well, my major concern here is again public awareness
and public participation in these hearings, and other means
of getting the word out to the people that there is a
definite threat and a definite health hazard.
I would like to say that I think a greater effort could
have been done on the part of the Environmental Protection
Agency to not only alert the media in the surrounding Region
but also to have incorporated or included in their press
release mailing lists of other states outside of Region
VIII. It is my understanding that just the Region VIII
media was sent these releases. I hope, I pray that the
-------
amount of plutonium that has already been created on the
spaceship is able to be gathered up, if you will, and sorted
or removed from the biosphere sufficiently. Covering it
with asphalt or other surface materials to fix, if you will,
it in the ground is not going to work for the next half a
million years, and that is what we are going to have to deal
with. I am really here not only talking for myself but for
my son and his children, and his children's children, and
his children's children's children. Only God should deter-
mine our genetic heredity.
I would like to at this point in time ask one of the
other coordinators who works with me at Environmental Action,
and who is active in other organizations, Mr. Morey Wolfson,
to come up and give some testimony that he has prepared, but
has not been included in the record. I do not know whether
you plan for him to speak later on, but if he could talk
now, that will be appreciated.
Chairman Mills: That will be okay, if you can confine
it.
Mr. Nunez: Are there any questions or comments?
Chairman Mills: Any questions for Mr. Nunez?
(No response.)
Mr. Nunez: I would like to say one other thing, that
nuclear power is not necessary. It should be like a last-
ditch effort when all else, all other energy forms have been
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483
totally exploited. We should not be producing these cancer
genetic materials. It just is not conducive to global
survival, and I would urge you to take into consideration
the global comments.
Dr. Snyder: I would like to comment especially on the
last statement. I take it from that statement then you are
of the opinion there is no carcinogenic risks from, say,
fossil fuels; that the risk is zero; that all others should
be exhausted before we enter on the nuclear fuels?
Mr. Nunez: I do not know. Maybe you cannot see the
lapel button that I have here, but it says "Solar Energy"
on it, and basically we are of the belief that the cleanest
and most abundant and evenly distributed source of energy
available to man at the present time and for all past decades
and for all future decades that concerns him is the sun. It
is indirectly the form of all the fossil fuels. If you
believe in the big bang theory, even uranium came from the
sun, and for that, hydroelectric and wind energy. All these
natural forms of energy are the alternatives that we should
be going toward if we are to survive as a species on this
spaceship.
Dr. Snyder: This just raises the question, what is the
hazard involved with these other forms of energy which have
not even been developed, you see, exxept in conceptual form?
What will their massive use entail?
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484
Mr. Nunez: The massive use and hazards involved with
solar energy development is really anyone's guess. If we go
with proposals, such as Peter Glasier's proposal with micro-
waving, collecting solar energy outside of the biosphere and
beaming it on down, which, by the way, Peter says is the
only thing that competes with LMFBR on an economic scale,
and apparently this is the thing that makes any sense in
this country is the almighty buck. Well, it could be catas-
trophous, I agree. We could disrupt the heat balance of the
planet and do worse harm possibly, but not probably.
Chairman Mills: What is the length of your comments?
Mr. Wolfson: Ten minutes. Before I start my testimony,
I would like to make a few generalized comments about the
way that this proceeding has taken palce.
First of all, the sound system, there is a very big
problem with that, and I would suggest that any time the
EPA, all of you are involved in a hearing, that you be
certain that the sound system is adequate.
Secondly, I would recommend that there be a rule of no
smoking at these hearings in the interest of public health.
Third, I would like to just underscore the statements
that have been made earlier about the fact that the public
information about this EPA hearing has not been adequate.
Also, I would just like to ask a question out of my own
personal curiosity. How many people here are from EPA right
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485
at this present minute?
(Whereupon, there was a showing of hands in the
audience.)
Chairman Mills: is that relevant?
Mr. Wolfson: Yes, this is an EPA hearing, so it is
very relevant.
My name is Morey Wolfson. I am a Coordinator for
Environmental Action of Colorado, People for Radional
Energy Sources, and the Rocky Flats Action Group. I have
served as a member of the Youth Advisory Board to the
Environmental Protection Agency and was past Associate
Director of Citizens Concerned About Radiation Pollution.
My interest in radiation pollution of the environment dates
back to the time immediately prior to the Rocky Flats fire
in 1969. Since that time, a major portion of my partici-
pation in environmental affairs has centered on positively
resolving this energy/environment conflict by increasing
the public's appreciation of the viability of solar
energy. I have received a Masters in Urban and Regional
Planning/Community Development at the University of
Colorado at Denver, where I have been employed by the
Bureau of Community Services and the Center for Urban
Affairs.
I am here today to discuss the consequences of the
potential contamination of the environment by radionuclides
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486
of the transuranic elements -- especially plutonium. It
is my understanding that the purpose of the hearing is to
learn of ways in which the EPA can protect the general
environment from radioactive material. The EPA has expressed
an interest in finding suitable limits on radiation exposure,
or levels, or concentrations, or quantities of radioactive
materials.
Due to the fact that scientists with special expertise
on radioactive levels are providing testimony at the hearing
today, my testimony will relate to the broader issues that
constitute the context in which a discussion of acceptable
levels center. These broader issues are necessarily an
integral part of the decision-making process process exer-
cised by the EPA, and therefore, have a useful function at
this public hearing. My scientific training does not allow
me to adequately direct comments to the more esoteric issue
of radioactive limits, but my experience has provided me
with information quite pertinent to this hearing.
It seems to me that the EPA is faced with the question
of how they should protect the general environment from
radioactive material. It is becoming generally apparent
that there are two basic approaches to environmental pro-
tection. Simply stated they are MITIGATION or PREVENTION
MITIGATION appears to be the most expedient, financially
rewarding, and most popular approach to the problem.
MITIGATION is a policy accepted by most Governmental
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agencies, planners, developers, and the like. MITIGATION
implies that SOME negative environmental impact is IN-
EVITABLE in certain development. Therefore, the objective
becomes to MINIMIZE that negative environmental impact as
much as possible.
The second approach to environmental protection is
PREVENTION. This does NOT presume the INEVITABILITY of a
certain project. It does not give a project as acceptable
or inevitable, but rather, prevention of environmental
damage accepts the fundamental existence of the CHOICE. In
the long-range view, when an environmental policy decision-
maker is opting for either the mitigation or prevention
course, the decision to prevent a dubious project will
become more cost-effective. That is to say, that if a
project must eventually be abandoned because of an inherent
environmental threat that is involved, it would be a much
sounder decision to abandon early on rather than attempting
to stop the project after it has already developed economic
and political momentum.
The EPA has the CHOICE to purposefully abandon the
nuclear course set by the Atomic Energy Commission, General
Electric, and Westinghouse, etc. In fact, the EPA has the
prime responsibility to assert that option. It is hard to
imagine that the EPA will ever be able to provide the public
with a guarantee that they have made arrangements for 100%
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containment of plutonium from the biosphere for a quarter of
a million years. That becomes rather apparent, without such
a guarantee, all we can expect are bland reassurances that
the levels of radioactivity are "within acceptable limits."
These reassurances, so often voiced by the outgoing AEC,
will not alleviate the feeling that the public is having
that their health is being compromised by the dubious
societal "advantage" of nuclear-generated electricity and
nuclear weapons. Should the EPA --by opting for mitiga-
tion -- risk the possibility of breaking the delicate
ecological chains that support human life as we know it?
It is my recommendation that the EPA fully recognize
the significance of the biological effects of ionizing
radiation. Any increase in the amount of radioactivity will
have a negative health effect. This information should lead
to an attitude that there is no "suitable" or "acceptable"
radiation exposure, level, or concentration.
At this point it might be instructive to outline the
source and uses of plutonium and some of the problems asso-
ciated with containment of the plutonium from the biosphere.
Plutonium is created in nuclear reactors for the purpose of
either creating material used in the production of warheads
or fuel for reactors. This man-made element is incredibly
toxic, has a half-life of 24,000 years, and has a pyrophoric
nature.
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Complete containment of plutonium has been -- and will
continue to be -- an impossible task. Plutonium has con-
taminated air, land, water, vegetation, humans, and other
animal life. With the continuance of nuclear arms pro-
duction and recycling, coupled with the exponential growth
expected with the advent of the fast breeder reactor, plu-
tonium recycling, the planetary inventory of plutonium will
be truly staggering in a relatively short time. We are
talking in 1975 about one fact of life, about a certain
amount of plutonium inventory on the planet. By the year
2020, we are looking at a very different kind of situation.
The decisions that you gentlemen make and the EPA makes
today is going to impact very heavily on that decision of
whether or not we are going to have these massive tonage of
plutonium in the future. Plutonium handling facilities have
already experienced theft, fires, and explosions.
After the expenditures of BILLIONS of dollars on plu-
tonium-related projects, Government and industry have failed
in every way to provide for safe plutonium containment from
the biosphere. In fact, this failure is so clearly recog-
nized by the insurance industry, that not a single American
dwelling has insurance covering radioactivity. The Price-
Anderson Act is a public subsidy and incentive to a Govern-
ment-spawned nuclear power industry. Why should a reactor,
or why should a plutonium-handling facility maximize on
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radiation containment when they won't be legally or finan-
cially responsible in the event of contamination?
Plutonium would obviously be released in the event of a
nuclear war. Now, this is very serious, and this is very
real, and could, in fact, be a major cause of radiation
pollution of the environment in the future. The global
environment has already been irreversibly contaminated by
radioactive fallout. A major nuclear war would undoubtedly
risk the genetic integrity of all mankind. Some scientists
have declared that full-scale nuclear warfare would be so
damaging that the radioactivity would prevent the birth of
children worldwide. In other words, if these scientists are
correct, nuclear warfare might mean the extinction of the
human race. I would just like to underscore that I am not
making this up. This is a global reality.
Chairman Mills: May I ask a question, getting off to
nuclear war, is that relevant to the establishment of plu-
tonium standards, or do you have any information? I fail to
get the connection here. Could you clear that up before you
go further?
Mr. Wolfson: As I read the eight-page EPA report
announcing the hearing that was generated by the Office of
Radiation Program, it clearly delineated the sources of
radiation pollution of the environment, and it did mention
that we are now exposed to radioactive fallout. The fact of
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the matter is that they way the momentum is building, we
will, in fact, have more radioactive fallout as a results 01
our activity.
Chairman Mills: Okay, fine.
Mr. Wolfson: Secondary effects of a nuclear war might
be just as catastrophic. Here I quote from Dr. Fred Ikle,
Director of the U, S. Arms Control and Disarmament Agency.
He says, "There is a possibility that a large number of
nuclear explosions might bring about the destruction,
or partial destruction, of the ozone layer in the strato-
sphere that helps protect all living things from ultraviolet
radiation. We know that nuclear explosions in the earth's
atmosphere would generate vast quantities of nitrogen oxides
and other pollutants which might deplete the ozone that
surrounds the earth. But we do not know how much ozone
depletion would occur from a large number of nuclear explo-
sions --it might be imperceptible, but it might be almost
total. We do not know how long such depletion would last --
less than one year, or over ten years. And above all, we do
not know what this depletion would do to plants, animals,
and people. Perhaps it would merely increase the hazard of
sunburn. Or perhaps it would destroy the critical links of
the intricate food chain of plants and animals, and thus
shatter the ecological structure that permits man to remain
alive on this planet. ALL WE KNOW IS THAT WE DO NOT KNOW."
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Dr. First: I think we are getting a little off the
topic, if you do not mind me saying so. I wish you would
speak on the subject of standards, because this is clearly
irrelevant.
Mr. Wolfson: I turn now to a producer and recycler of
the nuclear warheads which are poised for ecological suicide:
ROCKY FLATS. The American Friends Service Committee Rocky
Flats Action Group feels that there is patently nothing good
for humanity that can come from the manufacturing of more
atomic weapons. We have expressed our concern to the Atomics
International Division of Rockwell International, the new
contractors at the Rocky Flats Plant. Just last month
Former Secretary of the Air Force and now U. S. Senator
Stuart Symington said: "One miscaluclation, one sudden
terrorist activity, one paranoid leader, could set the spark
to a worldwide holocaust." The manufacturer of the nuclear
weapon, Rocky Flats, and the Governmental agencies, EPA,
employed to monitor and control the manufacturer will share
the responsibility of the use of the nuclear weapon.
ROCKY FLATS poses a unique ecological threat to the
Denver area. The threat must be removed. The initial
decision to site the plutonium handling facility near Denver
did not conform to siting criteria utilized in establishing
other nuclear facilities. The plutonium works at Hanford,
Washington, for example, were sited on a half million acres
of arid land in a remote location. General Leslie Groves,
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493
the head of the Manhattan Project, rejected siting a new
plutonium facility near Oak Ridge, Tennessee, Because he
"felt uneasy about the danger to the surrounding population.
Oak Ridge is not far from Knoxville," he said. "If a reactor
were to explode and throw great quantities of radioactive
materials into the atmosphere when the wind was blowing
toward Knoxville, the loss of life and the damage to health
in the area might be catastrophic." Apparently, this kind
of caution was not employed when siting Rocky Flats.
Dr. Edward Martell of the Colorado Committee for
Environmental Information, who so eloquently testified
today, has detailed the potential problems associated with
Rocky Flats. This is taken from, I believe, around 1970:
"In the not too unlikely event of a major plutonium release,
the resulting plutonium contamination of Denver could require
large-scale evacuation of the affected area, the leveling of
buildings and homes, the deep plowing and removal of topsoil
and an unpredictable number of radiation casualties among
people exposed to the initial cloud in the more seriously
contaminated areas. The human casualties and economic
losses from such an eventuality would greatly overweigh the
costs of relocating the plant before such an accident occurs."
Not long after the Rocky Flats fire, General Ciller,
head of the AEC's $800 million a year Division of Military
Application, was seeking $265 million to rebuild and remodel
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494
nuclear facilities.
Chairman Mills: Mr. Wolfson, we tried to accommodate
you, and I asked you how long it was going to take and you
said 10 minutes. You have been going on now for 15 minutes.
Mr, Wolfson: 1 have three more pages left.
Dr. Taylor: I suggest that a page of presentation is
25 lines, ten words per line, that takes two and a half
minutes.
Chairman Mills: You recognize, of course, that there
are a lot of other people --
Mr. Wolfson: Could you please tell me how long Dr.
Geesaman testified?
Chairman Mills: I am speaking to you, sir. Would you
try to summarize your statement now.
Mr. Wolfson: Yes. The information which I have been
providing to you, and, of course, I could go on as long as
Dr. Geesaman or as long as Dr. Martell with this type of
information. The reason you are trying to silence me
basically is because it is so sensitive that it gets into
the political area.
I would like to mention to you that I am a member of a
number of organizations that believe in citizen action,
political action. I want to let you know that we have
provided testimony on many occasions to many public hearings,
and on many instances we have been silenced as you are
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495
doing. However, we usually leave with a warning that says,
if you do not take care of this business on behalf of the
people of Denver and Colorado and the United States, do not
be surprised if two things happen. One, people do it anyway.
We supported, we worked and coordinated the initiative to
stop underground blasting in Colorado. We went before
hearings and we were closed down. We went before another
hearing, and we were closed down. We are going before this
hearing, and we are getting closed down. I am saying, do
not be surprised if there is going to be no nuclear power
plants in this country, and no nuclear warhead construction
in this country in the hear future, regardless of what you
do here.
The second thing is, is do not be disturbed if you
gentlemen lose your jobs as a result of not listening to the
public when they come to you at a public hearing.
That is a summary of my statement.
(Applause.)
Chairman Mills: Any questions?
(No response.)
Chairman Mills: Thank you very much.
-------
The Rocky Flats nuclear weapons facility, located fifteen
miles northwest of Downtown Denver, is one of the most threatening pieces
of property on the surface of the Earth today.
The super-secret Atomic Energy Conanission facility was
situated in Colorado in the early 1950's because the nuclear weapons
establishment wanted to conduct their work far from population centers.
Twenty years later, Rocky Flats is quickly becoming
encircled by a rapidly expanding (and enlightened) population.
Two thousand people are employed every day manufacturing
radioactive components for nuclear weapons. Trains and trucks traveling
through Colorado deliver and remove highly radioactive materials from
Rocky Flats regularly. The Atomic Energy Commission has permitted the
management to bury lethal materials that have escaped into the environment.
Plutonium, cesium, and tritium have been released into the
Metro Denver area- cc-.ca^inating t.ie 1-nd, air, and water.
Workers at the plant havs become unwitting nuclear guinea pigs.
Now that Colorado has elected new political leaders who are
conscious of environmental priorities, real action on Rocky Flats should
be forthcoming.
The votes to stop the Olympics and underground nuclear blasting
are a clear indication to public officials and Rocky Flats that the public
will not remain complacent to a health menace and a threat to global peace.
ROCKY FLATS WEAPONS PLANT MUST BE CLOSED DOWN!
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497
WHY IS ROCKWELL REPLRCING DOW?
The Atomics Division of Rockwell International will be
replacing Dow Chemical Company as the managers of the Rocky Flats facility.
Dow's mismanagement of the plant, as demonstrated by the hundreds of
accidents, spills, and fires that have occurred (including a $50 million
fire in 1969 that was the most expensive industrial fire in American
history) are the major reasons why Dow is being replaced.
WHRT KIND OFCOMPRNY IS ROCKWELL?.
Rockwell's products for the aerospace/defense market include
liquid and solid propellants, rocket engines, target drones, aircraft
air-to-ground missiles, and nuclear reactor components. Rockwell is also
th« prime contractor for the Air Force's B-l bomber program, which has
been declared obsolete before the first test flight.
25Z of Rockwell's total business is with the military.
Rockwell also manufactures power tools sold in many Denver
area hardware stores and UOOLCO department stores.
ROCKY FLRTS NUCLERR WERPON9
PRODUCTION MUST BE STOPPED?
Weapons production at Rocky Flats must be stopped, but
•topping it is not enough. Unless we change the policies and powers
responsible for Rocky Flats, there will be two or three new military
projects developed for every one that we stop. It is essential that
we work to end the "need" for Rocky Flats in the following ways:
-Challenge the crackpot logic of the MAD (mutual assured
destruction) arms race. Demand a serious commitment to
disarmament.
-Expose the self-serving narrow economic interests of
the military-industrial complex which is fed by unresponsive
politicians.
—Push for community and national planning for converting
the dominant automobile/petroleum and military/industrial
complexes into economic forces that serves humanity.
-Demand that politicians take clear-cut stands on the issue.
Sinoly setting up "study groups" is no raplacament for
action.
THE FORCES OF DEATH '-"HIGH HI-\V7 IN T" 3ALANCH, TK2 CRITICAL MOMENT
IS UPON US. US ARE ALL PPIS.'ISR OF V \3. IF HUMANITY DOES NOT PUT
AN END TO WAR, WAR WILL PUT AN END TO HUMANITY.
Your contribution-Is greatly appreciated:
The Rocky Flats Action Group
Z American Friends Service Committee
2801 East Colfax Avenue #304
Denver, Colorado 388-5896
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498
Text reprinted from
AMERICAN ASSOCIATION JJUJG
22 September 1972
Vol. 177, No 4054
x '• i or a '. ,s ?.tf CE
(Reprinted by permission from Science. Copyright 1972 by the American
Association for the Advancement of Science.)
Solar Energy: The Largest Resource
Not long ago, pro-
posals for using the
sun's energy were apt
^i . $ to be received with
^ considerable skepti-
cism. Within a few agencies of the f eder-
. al government and at an increasing num-
ber of university and industrial labora-
tories, that is no longer the case. Indeed,
perhaps the most impressive testimony
to the prospects for this type of energy
is the score of prestigious scientists and
engineers who have begun working on
methods for converting the sun's radia-
tion into forms more useful to man—
heat, electricity, or chemical fuels.
Within 5 years, many of these sci-
entists believe, solar-powered systems
for heating and cooling homes could be
commercially available at prices com-
petitive with gas or oil furnaces and
electric air conditioners. Still more sig-
nificant, but farther in the future, may
be means of using heat from the sun to
generate electricity; experimental solar-
thermal units have been constructed in
several countries, and several groups in
the United States are designing systems
to take advantage of improved materials
and manufacturing techniques. Even-
tually the direct conversion of solar
radiation to electricity by means of
photovoltaic cells or its bioconversion
to wood, methane, or other fuels on
a large scale may become economically
feasible.
Solar radiation is the most abundant
form of energy available to man, and
is so plentiful that the energy arriving
on 0.5 percent of the land area of the
United States is more than the total
energy needs of the country projected
to the year 2000. Sunlight is diffuse and
intermittent, however, and its use on
earth requires large areas to collect suf-
ficient amounts of energy and, for most
applications, the means to store energy.
Despite its abundance, solar energy has
not been exploited except in a limited
way in water heaters, furnaces, and
space applications; nor are the tech-
nologies that would allow widespread
To reap the tremendous amount of energy from the sun, Professor Aden Meinel and his wife,
Marjone, propose to cover areas of the Southwest with solar energy collectors. Inside these collectors,
gaseous nitrogen would be heated to temperatures of 1000° F. and then flow into tanks of
molten salts, capable of storing the heat for night-time use. Steam, heated by the molten salts,
drives turbines to produce electricity. The Meineis estimate that the power for a city of 60,000
could be supplied by one square mile of solar collectors.
use commercially available. Systems for
heating and cooling houses or for gen-
erating electricity with sunlight could
be built now, but they would cost more
than comparable systems that burn
fossil fuels. For some applications, how-
ever, the disparity in cost may rapidly
disappear as solar technology improves
and as the costs of fossil fuels rise.
Whether or not solar energy becomes
generally available in the near future,
there is growing agreement that this
source of energy will be important in
the long run. That being the case, pro-
ponents believe that it is the most un-
derfunded area of research in the energy
field, accounting for less than 1 percent
of federal research expenditures related
to energy.
Of the proposed uses of solar energy,
heating and cooling for homes and low-
rise commercial buildings are the most
developed and will almost certainly
constitute the first significant use of solar
energy in this country. Solar water
heaters are already in commercial use
in Florida and in several countries
overseas. Experimental houses have
been equipped with solar heating sys-
tems and preliminary development of
cooling systems has begun.
Solar Heating in the Home
For space heating, the solar collector
is typ'cally a black metal surface that
readily absorbs sunlight and is covered
with one to three panes of glass to re-
duce the heat loss. The glass is trans-
parent to the incoming sunlight, but
absorbs the longer wavelength radiation
emitted by the hot metal, so that a
"greenhouse" effect is created and the
effectiveness of the collector is in-
creased. The heat is collected in water
or air that is circulated through the
collector during the day, and part of it
is stored for release at night or in bad
weather. Hot water, hot rock, and chem-
-------
*f J J ical (change of phase) storage systems
have been experimentally tested, de-
pending on the type of heating system
envisioned (/).
For air conditioning, most investi-
gators believe, refrigeration systems that
depend on absorption of the coolant
fluid appear to offer the best choice.
Experimental cooling units are being
developed by several university and in-
dustrial research groups. At the Uni-
versity of Delaware, for example, a
group headed by K. W. Boer is design-
ing complete household energy systems
that would utilize heat pumps for space
conditioning* In other prototype sys-
tems, such as that developed by Erich
Farber*"at the University of Florida,
heat from the sun is used to drive am-
monia from an ammonia-water solu-
tion, and the ammonia is collected and
condensed. When cooling is needed, the
liquid ammonia is allowed to evaporate
and expand as in a conventional cool-
ing system, and the spent vapor is re-
absorbed in water.
For absorption refrigerating systems
to work smoothly, temperatures around
120°C or higher will be needed, and
thus solar collectors that are more effi-
cient than those for heating purposes
alone will be required. One possibility
may be surface coatings of the type de-
veloped ia recent years for space ap-
plications, which emit very little of the
solar radiation that they absorb and
which consequently attain higher tem-
peratures than uncoated metal col-
lectors. If such coatings can be pro-
duced on a large scale, their use might
help to reduce the cost of solar heating
and cooling, since collectors are the
most expensive item of a solar energy
system. Combined cooling and heating
systems, which have not yet been built,
are also expected to improve the eco-
nomic prospects for both 'because of
the joint use of the collector.
Substantial technical problems re-
main to be solved in the design of cool-
ing systems, in the manufacture of sur-
face coatings for improved solar col-
lectors, and in the optimization of com-
bined solar heating and cooling systems.
In most regions of the country backup
systems based on conventional fuels will
be needed for extended periods of bad
weather. Nonetheless, one estimate indi-
cates that if systems were commercially
*An explanation of "Solar One," the
house designed and built by K. W. Boer's
group, is available from EARS, in an
article titled "Turning on the Sunpower"
(Catalog No. 130A). See page 4 for
the address of EARS.
**A 12-page description of Dr. Faiber's
work, which includes 49 photographs,
is available through EARS (Catalog
No. 200A)
available now, solar heating would be
cheaper than electric heating in nearly
all of the United States and would be
competitive with gas and oil heating
when these fuels double in cost (2).
Proponents believe that solar heating
and cooling systems could ultimately
supply as much as half of the nearly
20 percent of total U.S. energy con-
sumption that is now used for residen-
tial and commercial space conditioning
and could reduce the peak use of elec-
tricity in summer.
For implementation of this technol-
ogy, however, some means to overcome
what are essentially social problems is
likely to be necessary. As Jerry Weia-
gart of the California Institute of Tech-
nology put it, "developing the technol-
ogy is not enough," because the frag-
mented building industry is traditionally
slow to adopt new techniques. Solar
heating systems, despite their lower fuel
costs, will entail higher initial costs,
thus discouraging consumer acceptance;
some observers have suggested that gov-
ernmental encouragement in the form
cult challenge, and there are conflicting
ideas about the best approach to the
problem. Some engineers believe that
small generating umts located where
the electricity is to be consumed are ilie
ideal way to utilize a resource that is
inherently diffuse and well distnbuied
This group favors the use of piv,o
turbines that would operate at ten j _i-
atures considerably lower than those
common in nuclear or fossil-fuel power
plants, despite the low thfrf?' "Ti-
ciency, between 10 and 15 peicen., ihat
these units would have. Others have
proposed large .solar-thenncl facilities
modeled o i fxis*.ng centiiu powci sta-
tions. The two concepts differ ho'h
philosophically and technically.
Smaii vapor turbines that used heat
from solar collectors to generate elec-
tricity were demonstrated by Harry
Tabor of Israel's National Physical
Laboratory in Jerusalem at the United
Nations conference on new sources of
energy, held in Italy in 1961. A min-
iature solar power plant in Senegal is
already in operation, and experimental
A model of the Meinels' proposed "Solar Power Farm." The black horizontal lines depict the solar
collectors.
of tax incentives or energy performance
construction codes should be part of a
national energy policy. The slow rate
of replacement of housing, in any case,
guarantees that several decades will
pass before a new heating system could
have a significant impact on total energy
use. Given the growing shortage of fos-
sil fuels, however, it seems clearly ad-
vantageous to move in that direction.
The generation of electricity with
heat from solar energy is a more diffi-
solar engines have been developed by
several investigators in the United
States. Typically, these units operate at
temperatures below 200°C. Their eco-
nomic advantages relative to other
sources of electricity have not been
demonstrated, and the concept has at-
tracted only limited interest, in part be-
cause of the difficulty of decentralizing
the present electrical generation and
distribution system.
Preliminary efforts to develop large
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too
central power plants are under way.
This concept has attracted considerable
interest, although substantial problems
remain to be solved before such plants
could be economically competitive. Still
higher temperatures, between 300° and
600°C, are required to operate modern
steam turbines, complicating both col-
lection of solar radiation and the stor-
age of thermal energy. To capture
enough energy at these temperatures,
mirrors or lenses larger than any yet
built will in all probability be needed
to concentrate sunlight. Because large
areas will be required—in most designs,
about 30 square kilometers for a 1000-
megawatt power station—the transfer
of heat from the far-flung solar collec-
tors to the generating facility is also a
complicated process. The cost and en-
durance of the collecting apparatus un-
der operating conditions is a critical but
undetermined factor.
Central Potter Station
One design proposed by a group
that is headed by Aden Meinel of
the University of Arizona would use
Fresnel lenses to focus sunlight onto a
stainless steel or glass ceramic pipe, thus
concentrating the solar flux ten times
above its normal value. The pipe is
covered with one of several types of
selective coatings that emit only a small
proportion, between 5 and 10 percent,
of the energy they absorb and is en-
closed in an evacuated glass chamber
to reduce conductive and convective
heat losses. Nitrogen gas is pumped
through the pipe at velocities of about
4 meters per second to transfer the heat
from the collectors to a central storage
unit. The Arizona team plans to use a
eutectic mixture of salts, mostly sodium
nitrate, as a heat storage medium; the
heat would be used to produce steam
for a turbine as needed. Liquid metal
or the molten salt mixture itself, despite
the greater difficulty in handling these
substances, might also be used to trans-
port heat from the collectors to the
storage unit.
A second group, headed by Ernst
Eckert of the University of Minnesota
and Roger Schmidt of Minneapolis-
Honeywell, Inc., has also begun work
on the central power station. Their de-
sign includes a self-contained, decen-
tralized system for collecting and stor-
ing solar heat. A parabolic reflector
would concentrate sunlight onto a heat
pipe, a device that can transport heat
along its length efficiently by convective
processes and that does not require a
fluid to be pumped through it. The
pipe's outer surface would be a selec-
tive coating, and the pipe would be en-
closed in an evacuated chamber. A
A laboratory model of the solar collectors proposed by the Meinels.
George Kew
small heat storage tank attached to each
heat pipe and reflector would complete
the unit; no centralized heat storage
facility would be used. Underground
pipes would bring water to each stor-
age tank and return it as steam directly
to a turbine—thus reducing the pump-
ing costs, the Minnesota team claims,
compared to the nitrogen system. In
addition, they believe, the self-con-
tained system would be easier to con-
struct and maintain.
The effectiveness of the selective
coating with which the collecting sur-
face is covered largely controls the
temperatures that can be achieved. Two
types of selective surfaces are known,
both of which absorb much of the in-
coming radiation—in the visible region
of the spectrum—but which emit only
a small portion of the infrared heat
radiation. Surfaces such as one devel-
oped by Minneapolis-Honeywell for the
Air Force rely on optical interference
between two reflective layers separated
by a transparent layer of the correct
thickness; ihm films of this type have
been routinely produced by vacuum
coating techniques in the commercial
manufacture of tinted glass for the ex-
teriors of new office buildings. A second
type of surface, developed by B. Sera-
phin at Arizona, is composed of silicon
or similar materials that naturally have
selective properties. Layers of silicon
and nonreflecting materials are laid
down on a highly reflective substrate by
chemical vapor deposition techniques;
the silicon absorbs sunlight, but trans-
mits mlrared radiation, so that the com-
posite surface has a high reflectance—
and hence a low emittance—in the in-
frared.
These selective coatings are partic-
ularly important for solar collectors
that are built without mirrors or lenses.
Simple planar collectors have several
advantages over the concentrating sys-
tems in that the concentrating collector
must focus sunlight on the absorber and
hence must follow the sun's motion in
the sky, machinery to allow daily track-
ing complicates the collector design. In
addition, focusing collectors operate
only on direct sunlight, whereas planar
collectors can utilize diffuse sunlight as
well—and thus can function in cloudy
or hazy weather Because the perform-
ance of some of the most selective coat-
ings decreases markedly at high temper-
atures, however, power plants using
them would have to operate at temper-
atures below 350°C, with correspond-
ingly reduced efficiency in the steam
turbines. Improved selective coatings
may allow planar collectors—which
Meinel and his co-workers believe, in
principle, to be the most effective in
areas of the United States other than
the cloudless Southwest—to be used.
But most initial designs are based on
the assumption that concentration of
the sunlight will be necessary, and in
these systems the fabrication, cost, and
durability of the concentrators are the
major concern.
The trade-offs between different types
of collectors are not the only feature of
the design of solar thermal plants still
open to debate. Even with concentrating
collectors, it may prove advantageous
to operate the system at a reduced tem-
perature, according to the Minnesota
team. Their analysis shows increasing
efficiency of the collectors, but decreas-
ing efficiency of the thermodynamic
cycle of the turbines as the operating
temperatures are reduced, with the op-
-------
timum temperature dependent on de-
tailed design of the system and on the
heat storage medium chosen. Heat pipes
of the size envisioned have never been
built, and other hardware details remain
to be considered.
Both groups of investigators believe
that the cost of solar-thermal plants
will be not more than two or three
times what fossil-fueled or nuclear-
generating plants cost now, and that
rising fuel costs will eventually tip the
balance in favor of solar-thermal plants
whose fuel is "free." Before accurate
estimates of costs can be made, they
agree, more detailed engineering studies
and some additional research are nec-
essary. But Meinel, at least, believes
that full-scale solar-thermal power plants
could be built as early as 1985 with an
adequate research effort. Other esti-
mates are somewhat less optimistic,
but a group of western utility com-
panies is considering the development
of a small solar-powered facility that
could serve as a prototype for peak load
applications.
Although solar energy has probably
the fewest potential environmental prob-
lems associated with its use of any of
the major sources of energy, some prob-
lems, none of which appear to be in-
superable, do exist. Collecting surfaces
absorb more sunlight than the earth
does, and while this is not likely to
alter the local thermal balance in house-
hold or other small-scale use, the larger
expanse of collecting surface m a cen-
tral power plant might. Thermal pollu-
tion will also be a problem if water-
cooled turbines are used—indeed, more
so than with nuclear power plants be-
cause solar installations are expected
to have even lower thermal efficiencies.
If waste heat is returned to the at-
mosphere, it could help to restore the
local thermal balance. The effects of
small changes in the thermal balance
would depend on the local meteorologi-
cal conditions, but are expected to be
small. The lack of paniculate emissions
or radiation hazards might allow solar-
thermal power plants to be built close
enough to towns or industrial sites so
that their waste heat could be put to
use. Finally, like other industrial facili-
ties, large-scale plants would also carry
some risk of accidents, with the attend-
ant possibility of leaking heat transfer
or storage media into the environment.
Yet another option for generating
electricity with sunlight is direct con-
version by means of photovoltaic cells.
But the cells available now—which
were developed for space applications—
are relatively inefficient and very ex-
pensive to manufacture. As a long-
term prospect, however, both cadmium
sulfide and silicon cells are attracting
considerable attention. This option, and
the bioconversion of sunlight to fuels,
will be discussed in future articles.
Space heating and cooling with solar
energy are not available today. Solar-
thermal power plants have yet to be
built on any but the smallest scale, and
key elements of the necessary technol-
ogy have not been adequately demon-
strated. But both options appear to be
close enough to practical tests of their
economic feasibility to warrant in-
creased efforts. The ancient dream of
power from the sun may not, after
all, turn out to be impossible.
—ALLEN L. HAMMOND
References
1. Proceedings of the United Nations Conference
on New Sources of Energy, Rome, Italy
(Unned Nations, New York, 1961).
2 R Tyhout and G. Lof, Natur. Resour. J.
10, 268 (1970).
Copyright 1972 by the American Associa-
tion for the Advancement of Science.
Reprinted by EARS
Environmental Action Reprint Service
University of Colorado at Denver
1100 14th Street
Denver, Colorado 80202
Phone (303) 534-1602
Distributed by:
501
INDUSTRY SOLAR ENERGY PLAN TO BE URGED
By Don Kirkman
Scripp;>-Howard Staff Writer
WASHINGTON - The government is
about to ask private industry to begin
developing solar-powered heating and air
conditioning equipment.
The National Science Foundation
(NSF) will offer a number of compet-
ing giant corporations contracts to study
the possibilities of producing solar energy
equipment for use anywhere in the nation
with only minor changes foe local climate
variations.
The request will mark the govern-
ment's first major effort to harness the
sun as a partial answer to the nation's
deepening energy crisis.
As now conceived, the solar energy
heating and air conditioning program will
take at least five years and proceed in
three phases, NSF officials said. The first
phase will comprise the upcoming study
contracts, the second will develop equip-
ment, and the third will test the equip-
ment in homes, apartments, industrial
plants, schools and public buildings.
The solar energy idea was proposed
by President Nixon in 1972, given a
modest $3.8 million allocation in the
government's fiscal 1973 budget and up-
graded to $12.3 million in the proposed
fiscal 1974 budget. Even larger funding
for the program is expected m later years
NSF officials said.
Currently, solar energy is little used
in the United States in comparison with
other nations, said NSF's Donald Beattie,
but the technology for a vast new in-
dustry already exists. Thus, the NSF's
solar energy program aims at providing
seed money to stimulate such an industry.
At best, no more than 25 American
homes or buildings now are heated by
solar energy, most of them curiosities
built by avant garde architects or uni-
versity groups.
Interest in solar energy has been spur-
red in recent years by NASA's successful
and widespread use of the technique to
provide electricity on board spaceships
and satellites.
Beattie noted that the equipment NSF
hopes will be developed will not neces-
sarily replace conventional heating units.
But, he said, in some areas it could cut
by 50 to 70 per cent demands fo* elec-
tricity, natural gas and oil by supplement-
ing those conventionally powered heating
units and air conditioners.
NSF expects most of the solar energy
equipment to use glass sheets as a roofing
material to focus the sun's rays into a
chamber. The heat generated in this cham-
ber would then be circulated through
the building. The same system also would
be used to heat water and power air-
conditioning units.
By 1985, the NSF believes 10 per cent
of the nation's new buildings will be
equipped with solar energy equipment
for heating and cooling. Additionally, the
NSF estimates that by the year 2000
about 35 per cent of all heating and
cooling in the nation will be by solar
energy and 20 per cent of the nation's
electricity will be generated by the sun.
"Nobody ever has made a concerted
attempt to make solar energy a feasible
way to heat and cool buildings," Beattie
commented. "We're trying to take solar
energy out of the realm of being a
curiosity and make it a workable, feasible
reality."
Any workable systems developed by
the NSF will be offered to private in-
dustry for mass production.
Government installations may be
among the first customers for the new
equipment, Beattie noted, with the Army
and General Services Administration in-
terested in solar heating for military
bases and federal buildings.
Reprinted with permission from Rocky Mountain News, April 30, 1973
-------
fl)2
(Reprinted by permission of the Bulletin of the Atomic Scientists.
Copyright (c) 1971 by the Educational Foundation for Nuclear Science.)
Nuclear Power and Ecocide:
An Adversary View of New Technology
With his Lawrence Radiation Laboratory colleague, Arthur R. Tamplin,
John W. Go/man, M.D., is a leading critic of the Atomic Energy Commis-
sion's radiation safety standards. In this article, he relates the radiation
controversy to the broader issue of technological motivations in American
society. He proposes an adversary method ol controlling ecologically
unsound or dangerous technical innovations. He suggests that the de-
velopment ot a sustaining body of technological criticism and challenge
is incumbent on the scientific community. Dr. Gofman is professor ot
medical physics at the University of California, Berkeley, and former head
of the Biomedical Division at the Lawrence Radiation Laboratory, Liver-
more, where he now conducts research.
JOHN W. GOFMAN
Our society is based upon the premise that ini-
tiative, innovation and promotion, all leading to
economic profit, will by their very nature insure
the delivery of goods and services that will steadi-
ly upgrade the quality of life for the greatest
number. It does seem reasonable to suggest that
with the extremely viable enterprise system we
have, with the obvious talents and accomplishments
of our scientists and engineers of a variety of spe-
cialty disciplines and with abundant resources and
a beautiful land, we should easily be able to create
this high quality life for any reasonable-sized popu-
lation in the United Stales.
The present environmental crisis clearly indi-
cates that such a desirable result is anything but
automatic. The threats posed by food adulteration,
poisonous chemicals of agriculture and commerce,
and radioactivity may individually, or by syner-
gistic activity, guarantee ecocide.
Science and technology are prominently applied
in the service of the established system whatever
be the privileged currency. And this means that
large scale change comes very quickly and can af-
fect the entire population of the country. We have
learned, to our dismay, that there may exist serious
secondary implications of technological innovations,
or of by-products of such innovations. These can
take the form of severe environmental degradation
or of an uncertain debt, in the form of a future
health burden to society. It would seem to accrue
to the advantage of a nation, even ultimately to
survival itself, to anticipate the secondary, or ad-
verse, effects of technological innovation upon so-
ciety. We do not have appropriate institutions
which will guarantee an early alert to potential,
possibly subtle, secondary effects of technology.
If no early feedback information becomes available
concerning potentially detrimental consequences,
the technologically-based industry grows apace,
and the unanticipated detrimental effects will nec-
essarily afflict the entire population. This is dan-
gerous, and it would seem to compel rational hu-
mans to place a premium value upon comprehen-
sive foresight.
Once an enterprise is launched, we are faced
with a new set of imperatives. And these impera-
tives grow, probably as a power function, with the
investment in the venture. What are these -"in-
vestments"?
The entrepreneur invests capital. Big capital.
28
Reprinted by permission of Science and Public Affairs, the
Bulletin ot the Atomic Scientists. Copyright 1971 by the
Educational Foundation for Nuclear Science.
-------
503
Today, endeavors of any consequence even worth
considering here are very big business, encompas-
sing in a short period of time the efforts to dis-
tribute goods and services to 200 million people
nati6nally, and to even larger numbers when for-
eign outlets are considered. If the particular tech-
nological entrepreneurial project has gone along
for a reasonable period, the capital funds commit-
ted can be huge. It is then indeed a matter of
considerable importance concerning which the en-
trepreneur must be extremely protective. Losing
money is not the way privilege is preserved and
extended.
The scientists and technologists invest career
and economic opportunity. Indeed, they often pre-
pare themselves at great cost for a particular en-
terprise. And if the technology has persisted for
any length of time, such men have achieved posi-
tion, prestige and a very high personal economic
stake in the future of the enterprise. A case in
point is the nuclear energy technology. Whole
university departments have devoted themselves
to the training of nuclear engineers and related
technologists. Beyond the educational level, there
are thousands of nuclear engineers, health physi-
cists and biomedical scientists with well-established
careers predicated upon the continuation and
growth of nuclear energy technology, in particular
nuclear electricity generation. And this doesn't
begin to take into account the lower echelons, some
140,000 atomic industrial workers, with a large
stake in the continuation and growth of this in-
dustry. Indeed, the governmental regulators them-
selves have a not inconsiderable stake in the nu-
clear energy enterprise.
Optimism Common
These are not precisely the ingredients for a
continuous process of self-examination, searching
criticism or the discovery of undesirable secondary
effects of a particular technology. It is common
to find an amazingly unbroken wall of optimism
about the future promise of the technology for
"mankind."
The elite among the scientists and technologists
who promoted the enterprise to the entrepreneurs
have a major investment of ego, prestige and posi-
tion. These men have generally committed them-
selves to the glowing promises of the technology
in full public view. Again, the longer the enterprise
has persisted before possibly adverse features be-
come evident, the greater is the ego-prestige com-
mitment of such elite, and the more difficult it-
becomes for this elite group to reverse its position.
In nuclear energy, one might consider the diffi-
cult position of AEC Chairman Glenn T. Seaborg,
who has proudly admitted his position as a prime
salesman for nuclear electricity generation, and
his intention to create a plutonium future for us
all. From a myriad of platforms, and in countless
printed statements, he has stated, "The atom came
to us in the nick of time " Is it. therefore, truly
difficult to understand why Dr. Seaborg is having
difficulty facing the realization that the hazard
of ionizing radiation is far greater — 20 to 30
times greater — than was thought a decade ago?
Is it difficult to understand why Dr. Seaborg dodges
the question of the likelihood of a catastrophic
accident at a nuclear power plant?
Is it difficult to understand why Congressman
Chet Holifield, having pushed appropriations of
billions for nuclear energy development through
Congress, clings to a thoroughly discredited con-
cept of a "safe" amount of radiation exposure?
The evidence he cites for the concept of "safe"
doses of ionizing radiation has been rejected by
a whole series of distinguished scientists, as well as
all the scientific bodies involved in the study of
radiation hazards.
Unrealistic Hopes
It should be unrealistic for any of us to
hope that dangerously misguided technological-
industrial endeavors are going to come to an end
through: (a) Economic suicide of the capital-
investing entrepreneur, (b) Career and job suicide
of the technologists and workers, or (c) Ego and
prestige suicide by leaders, promoters and apolo-
gists for the enterprise. To argue that a higher
morality should guide any of these groups, with
their varied vested interests, is simply to produce
a totally unreal and unrewarding image of men.
It is obvious that long-range ecocide will necessari-
ly win out over short-range, parochial economic
suicide, career suicide or ego, prestige suicide. And
morality won't even visibly enter into the consid-
eration, for the mechanism of rationalization will
surface in abundance to protect against even the
most obviously indefensible position.
There are those who believe that government
will take the necessary steps to seek out adverse
side effects of technology, especially in this new age
of environmental awareness. This idle dream ne-
glects the fact that once an enterprise is well along,
government and enterprise are snuggly bedded down
together. To be sure, there will be an occasional,
restrained rebuke from a regulatory agency, a mild
ritual of wrist-slapping, and even a token fine.
Nothing more is to be anticipated.
Still others hope that a deep sense of public re-
sponsibility will motivate some scientists, technol-
ogists or elite within the enterprise to speak out
in the public interest. There are several reasons
why this fond hope will accomplish but little. Few
within the enterprise will speak out for reasons
previously cited. If they do speak out, they will,
in general, be demolished by the public relations
steamroller of the enterprise, aided and abetted
silently or loudly by their colleagues within the
enterprise itself.
Lastly, citizen groups may try to stop an eco-
destructive enterprise. Noble as many of these
have been, they are pitifully under-financed and
no match for the professionals of the entrepreneu-
September 1971 Bulletin of the Atomic Scientists 29
-------
F04
rial juggernaut. We have yet to see a major victory
in this arena.
There really does exist a constituency for pre-
serving a livable world, one that is not strictly
limited to the "little man," fortunately. As F.
Lundberg pointed out in "The Rich and the
Super-Rich,'' even the pursuers of privilege view
with dismay some of the depredations of their
confreres. Among scientists and technologists there
are many who are enthusiastic environmentalists
and ecologists for all technologies but their own.
And there is the constituency of women who are
possessed of a strange, but vehement, desire to
have their children grow up with a reasonable
chance to survive. Altogether these groups possess
considerable clout, provided it can be effectively
mobilized. That is, there are several essential in-
stitutions that must be developed. And all of them
are essential if the desired goal of transition of
anti-societal to pro-societal enterprise is to be
achieved.
The broad constituency just described must in-
sist that we develop — at the earliest possible mo-
ment — centers of technology assessment, out-
side the reach of the enterprises or government
bureaucracies. The explicit responsibility of such
centers should be the development and presenta-
tion of an effective adversary position on the im-
plications of on-going and new technologies. The
successful execution of this mission would require
high scientific competence. The reports of such
"adversary" centers should be made widely avail-
able directly to the public. And a mechanism must
be set up for an open-forum dialogue between the
promoters of the technology and the adversaries.
If an adversary position is developed before mas-
sive investment is committed, even entrepreneurs
will be quite interested. They are not unaware
that much of the advice rendered them by their
own advisers has been poor in the past. But for
those technologies that are far advanced, the
numerous types of investment previously described
represent a powerful combination. Even the most
rational, convincing adversary position will not
turn things around without additional features.
Technological unemployment, or the fear of un-
employment, must be abolished. So long as this is
not accomplished, the technologists-scientists in a
particular technology cannot possibly be objective
in an assessment of their own technology. Objec-
tivity is readily buried in a morass of pseudoscience
and rationalizations if the disappearance of posi-
tions and careers threatens. The labor force in a
particular technology can also provide a powerful,
unfortunate lobby to obscure a public objective
evaluation of the technology and its hazards.
If both of these groups (technologists and labor)
are to participate in a constructive re-direction of
technological enterprise, where required, it is es-
sential that they be protected against the prospect
of unemployment. It must become mandatory that
conversion jobs be provided, without loss of posi-
tion level or salary level when a particular tech-
nology is discontinued And I would urge that
scientists-technologists form a powerful, deter-
mined organization, cutting across specialty boun-
daries, to demand an end to the pernicious insti-
tution of unemployment. For those who might ar-
gue that this is unprofessional, I would suggest
they are contributing to the prospect of ecocide.
And labor should, of course, insist upon the aboli-
tion of unemployment and fear of unemployment,
too. If fear of unemployment is eliminated, con-
version from anti-societal to pro-societal enterprise
becomes possible. If the threat of job loss persists,
the prospects for a rational approach to conversion
are dim indeed.
There is no doubt that the privilege system has
found the fear of unemployment to be an extremely
useful tool in the past to keep all levels of em-
ployees in line, obedient and servile. Possibly this
luxury accorded themselves by the entrepreneurs
in the past can only be criticized as diabolical and
inhumane. In a technological era, where misdi-
rected enterprise can provoke potential eco-disaster,
such a luxury simply cannot be afforded.
Economic details undoubtedly will require some
imaginative efforts. One of the ways to stimulate
imaginative effort is to develop a very powerful con-
stituency insisting upon an early solution. This
particular economic problem does not appear to
be one of the most profound ones that man has
faced.
At the economic-entrepreneurial level, the nec-
essary ingredient is indemnification against loss of
capital investment, when technology assessment
dictates a change in direction. A punitive approach
to investors in technology-based enterprises which
turn out to be ecologically unsound seems to ap-
peal to some. However, such an approach can
30
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S05
only be expected to meet with fierce resistance;
subterfuge, distortions, half-truths and lies in the
effort to preserve short-term, parochial economic
interest, whatever the societal cost. Certainly the
effective implementation of an adversary technol-
ogy assessment very early in the course of new
technologies would minimize the need for indem-
nification, simply because obviously misdirected
ones would not get off the ground so easily as they
do now. But even with the best of alert systems,
the secondary, adverse effects of some technologi-
cal innovations will not become evident early. The
fear of capital loss is, without doubt, a fantastically
powerful motivating force to continue even the
most blatantly eco-mad endeavors. It is difficult
to believe it is more economic to continue on the
road to oblivion than to indemnify investors so
they will at least not fight with desperation against
a rational change of direction.
Evaluating Reactors
Nuclear electric power technology certainly is
one which comes up for consideration. Obviously
there exists a wide range of opinions concerning
whether the current program of heading toward a
plutonium-based energy economy makes sense. A
considerable segment of thought holds that the
current burner reactor-electricity program makes
no sense whether or not there is a future breeder
energy economy. It is extremely difficult to be-
lieve that a rational evaluation of this problem
can take place under circumstances where some of
our giant corporations would stand exposed with
the capital stake they hold in this enterprise.
But it is even more difficult to believe that the
cost of conversion, including indemnification, can
possibly approach the cost of continuation with
potentially disastrous enterprises. In an economy
which sustains some $70 billion of annual dump-
ing into obsolescing and useless armaments, it
seems that the indemnification costs of redirecting
enterprise cannot be forbidding. Talent, training
and many of the facilities can readily be salvaged
to embark upon societally useful ventures. In the
case of electric power generation, scrapping the
nuclear electricity program will still require talents,
facilities and organization to proceed with ap-
proaches to environmentally sound generation of
electric power. The industrial giants are not going
to disappear in any event. It is sensible to have
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506
them doing something that meets societal needs
rather than something which thwarts human sur-
vival. If this be ransom, I would consider it well
worth paying. Maybe, one day, a more rational
approach will become available, but we don't have
time for the appearance of utopia.
We are a culture that worships "success." And
we all repeat the maxim, "nothing succeeds like
success." But we don't really understand the full
implications of this maxim. Economics of conver-
sion of mis-directed technology has been discussed
above. But economics is really not the whole story
in leading to persistence in technological blunders.
While thinking about the wonders of "success,"
we must give some real consideration to "failure."
We place such a high ego-premium on being right
about what we say, what we do, especially for all
endeavors that are in the public or semi-public
domain. It is no secret that in scientific academe
some men appear to devote a lifetime of research
and publication to proving they were right in
their Ph.D. thesis. Who in industry or technology
in general is unaware of the ego-hazard (over and
above hazard of job loss) inherent in having to
tell his superior that all is not so rosy in the pic-
ture painted last month or last year concerning a
specific project? Defensiveness is the obvious re-
sult of the high value-premium we place upon
success. And defensiveness breeds tunnel-vision,
self-deception and rationalization — anything but
objectivity.
Motivations and Men
This cult of success pervades our education sys-
tem, produces the wrong kind of competition and
virtually insures that human values will be given
low priority. We must give men the opportunity
to be commended for being self-critical, for being
able to conclude that their prior opinions were
in error. There is no doubt that the change in
attitude with respect to this issue, much more
subtle than the economic ones, will require very
careful nurturing. It won't be easy to have people
appreciate how important it is to honor those
who can forthrightly admit error or failure. While
this may prove difficult to achieve, it seems we
must work toward it if we are to avoid compound-
ing our mis-moves in technological application.
Science and technology, applied in large-scale
enterprise, can contribute heavily to the improve-
ment in quality of life. And, alternatively, such
application can and does lead to environmental
degradation, as well as the imposition of potentially
unbearable burdens upon future health and well-
being. Unfortunately, the mechanisms required
to determine which of these end results is more
likely to be the outcome are largely absent. It is
all too easy in such a state of affairs to place blame
upon bumbling bureaucracies or upon insensitive
corporations. But decisions to go forward in en-
terprises, based upon technological innovation, are
not made either by corporations or by bureau-
32
cracies. Such decisions are made by men. It is
perhaps more pleasant to shy away from this
reality because it brings us face to face with defects
all of us share. Men, at all echelons of society, are
motivated by ego-security, fear and economic con-
siderations. The economic considerations range
from privilege and its extension through to simple
job security for avoidance of poverty.
In the longer range, perhaps the counterproduc-
tive aspects of these motivations may be recognized
and men may change. But technology presents us
with hazards operating in a much shorter time
frame. So we must try to solve our problems as
we are. This means recognizing defects which exist
and endeavoring operationally to counter them.
One defect is the absence of a viable institution
for critical assessment of on-going or proposed tech-
nologies. We can rest assured that the favorable
prospects for such technologies will be amply de-
veloped — and widely advertised. We have, at
present, no sound method of insuring that poten-
tially adverse effects will receive independent, un-
biased consideration. Lip service to this effort we
have had, and will have, in profusion.
The Next Step
This particular defect can be rectified through
the development of a reprisal-free adversary sys-
tem of scientific inquiry. While such a system is
vitally needed, it will provide only a first step.
The next step is the creation of rational, open-
forum dialogue, the goal of which is a reasonable
constructive evaluation of the pro and con infor-
mation and implementation based upon such eval-
uation. Neither the evaluation nor the implementa-
tion will conceivably accomplish anything worth-
while unless we face squarely the real, powerful,
underlying motives of men. And these relate al-
most wholly to economic motives; secondarily to
ego-preservation. The economic motives are pri-
mary here. If we indemnify the entrepreneurial
elite and abolish the prospect of economic insecur-
ity all along the chain from top management and
top technologists through to the labor force, we
may yet see a very reasonable approach to evalua-
tion and implementation. The ego-defensiveness
problem is, in part, related to economics and, in
part, related to some required changes in our cul-
tural attitudes.
I would expect two answers to these proposals.
First, the problem lies in other directions. How
dare you make such a brazen analysis of reality?
To this I would reply that the time for tranquil-
izers is over. Second, insuperable economic hur-
dles would prevent iniplc*"ientatioi! (-1 thf-se mv
posals. This is why i would suggest the dfVfc!',>j>
ment of a powerful activist constituency to demand
that the economic hurdles H« overcome. 1 suspect
there is a chance for some imaginative progress
even in economics once it is realized that the heat
is on and will stay on. Ecocide )£ *oo high a price
to pay for nonimaginative lethargy.
-------
507
John W. Gofman and Arthur R. Tamplin
The Case Against Nuclear
Power Plants
• In one year's operation, a single nuclear
power plant generates as much radio-
active poison as one-thousand Hiro-
shima-type atomic bombs!
• Insurance companies — experts on
judging risks — protect themselves
against anticipated claims from private
citizens for nuclear plant accidents and
radioactive damage by specifically ex-
cluding such coverage in contracts.
• The AEC — designated as the public's
"protector" — is charged with promoting
the nuclear industry. This is an impos-
sible conflict of interest.
• There is "not a shred of evidence" that
AEC radiation standards for peaceful use
of the atom are truly safe.
• Nuclear power is not the sole adequate
source of electricity for the future. There
are efficient alternatives — cleaner,
cheaper, safer ones.
In 1963 the Atomic Energy Commission
asked Dr. John Gofman and Dr. Arthur
Tamplin to undertake a series of long range
studies on potential dangers that might
arise from the "peaceful uses of the atom."
Assuming that the Atomic Energy Commis-
sion seriously wanted to know the truth
about the safety of nuclear electricity and
its generation, the authors attacked the
problem with gusto.
Here's what they learned:
1. Radiation from rapidly expanding
Atomic Energy programs is a far, far
more serious hazard to human life
than anyone had ever conceived it to
be.
2. Atomic radiation will result in many
times more deaths from cancer and
leukemia than previously thought
possible. The potential damage to
future generations from genetic dam-
age has been even more grossly un-
derestimated.
But far from having their findings wel-
comed, Gofman and Tamplin experienced
a torrent of personal and professional con-
demnation from the nuclear triumvirate —
the U.S. Atomic Energy Commission, the
Joint Committee on Atomic Energy, and
the Electrical Utility Industry. The authors
attribute this to their announced unshake-
able conviction that the entire nuclear
electricity industry was — and still is — de-
veloping under a set of totally false illu-
sions of safety and economy. This judg-
ment was inimical to the interests of all
these groups.
Poisoned Power is a starkly realistic
book. It is also a hopeful one, for the au-
thors firmly believe that citizen action can
combat the nuclear power group's care-
fully contrived propaganda campaign. To
help the citizen to navigate through the
murky and controversial areas of debate
Gofman and Tamplin provide an appendix
containing the most frequently raised
questions on the merits of nuclear power,
with clear, direct answers. Poisoned Power
shows that we can have the electric power
we need to maintain our high quality of
life. And we can do it without destroying
our environment through the introduction
of radioactive poisons that will last, es-
sentially, forever.
Finally, the authors make a revolutionary
proposal — an Adversary System of Scien-
tific Inquiry, which will open all new tech-
nologies of national scope to serious, ob-
jective scrutiny by qualified scientists.
These men would be specifically charged
with exploring each proposed develop-
ment with an eye to uncovering possible
physical, social or economic hazards.
These points would then be weighed
against any advantages by the scientific
community and the lay public before fur-
ther development of the technology would
be permitted. The authors believe such a
system would long ago have postponed
the proliferation of nuclear power stations
to allow for detailed investigation into their
safety and efficiency compared with al-
ternate sources of power
RODALE PRESS
PB-30
Reprinted by EARS
Environmental Action Reprint Service
University of Colorado at Denver
1100 14th Street
Denver, Colorado 80202
Phone (303) 534-1602
Distributed by:
-------
^ Denver Post, Su
nday, Nov. 25, 1973
The Morality of the
Nuclear Energy Issue
by Allen V. Kneese
Editor's Note: In its original form,
this article was a statement submitted
to the Atomic Energy Commission (AEC)
in response to a request for comments
on one of its documents. The document
noted that environmental reports for a
nuclear power reactor should contain a
cost-benefit analysis which, among other
things, "considers and balances the ad-
verse environmental effects and the envi-
ronmental, economic, technical and other
benefits of the facility."
I am submitting this statement as a
long-time student and practitioner of
benefit-cost analysis, not as a specialist
in nuclear energy. It is my belief that
benefit-cost analysis cannot answer the
most important policy questions asso-
ciated with the desirability of developing
a large-scale, fission-based economy.
To expect it to do so is to ask it to
bear a burden it cannot sustain. This is
so because these questions are of a deep
ethical character. Benefit-cost analyses
certainly cannot solve such questions and
may well obscure them.
These questions have to do with
whether society should strike a Faustian
bargain with atomic scientists and engi-
neers.
If so unforgiving a technology as
large-scale nuclear fission energy pro-
duction is adopted, it will impose a
burden of continuous monitoring and
sophisticated management of a dangerous
material, essentially forever. The penalty
of not bearing this burden may be unpar-
alleled disaster. This irreversible burden
would be imposed even if nuclear fission
were to be used only for a few decades, a
mere instant in the pertinent time scales.
Clearly, there are some major advan-
tages in using nuclear fission technology,
else it would not have so many well-
intentioned and intelligent advocates.
Residual heat is produced to a greater
extent by current nuclear generating
plants than by fossil fuel-fired ones. But,
otherwise, the environmental impact of
routine operation of the nuclear fuel
cycle, including burning the fuel in the
reactor, can very likely be brought to
a lower level than will be possible with
fossil fuel-fired plants.
This superiority may not, however,
extend to some forms of other alter-
natives, such as solar and geothermal
energy, which have received compara-
tively little research and development
effort. Insofar as the usual market costs
are concerned, there are few published
estimates of the costs of various alter-
natives, and those which are available are
afflicted with much uncertainty . . .
Unfortunately, the advantages of fission
are much more readily quantified in the
format of a benefit-cost analysis than are
the associated hazards. Therefore, there
exists the danger that the benefits may
seem more real . . . Here we are speaking
of hazards that may affect humanity many
generations hence and equity questions
that can neither be neglected as inconse-
quential nor evaluated on any known
theoretical or empirical basis.
This means that technical people, be
they physicists or economists, cannot
legitimately make the decision to gener-
ate such hazards. Our society confronts
a moral problem, of a great profundity; in
my opinion, it is one ol the most conse-
quential that has ever faced mankind. In
a democratic society the only legitimate
means for making such a choice is
through the mechanisms of representa-
tive government.
For this reason, during the short inter-
val ahead while dependence on fission
energy could still be kept within some
bounds, I believe the Congress should
make an open and explicit decision about
this Faustian bargain.
This would best be done after full
national discussion at a level of serious-
ness and detail that the nature of the
issue demands. An appropriate starting
point could be hearings before a com-
mittee of Congress with a broad national
policy responsibility . . . Another possibi-
lity would be for the Congress to appoint
a select committee to consider this and
other large ethical questions associated
with developing technology. .
Much has been written about hazards
associated with the production of fission
energy. Until recently, most statements
emanating from the scientific community
were very reassuring on this matter.
But several events in the past year or
two have reopened the issue of hazards
and revealed it as a real one . . .
The recent failure of a small physical
test of emergency core cooling equipment
for the present generation of light-water
reactors was an alarming event. This is in
part because the failure casts doubt upon
whether the system would function in
the unlikely, but not impossible, event
it would be called upon in an actual en-
ergy reactor. But it also illustrates the
great difficulty of forecasting behavior
of components in this complex tech-
nology where pertinent experimentation
is impossible. Other recent unscheduled
events were the partial collapse of fuel
rods in some reactors.
There have long been deep but sup-
pressed doubts within the scientific com-
munity about the adequacy of reactor
satety research vis-a-vis the strong em-
phasis on developing the technology and
getting plants on the line. In recent
months the Union of Concerned Scien-
tists has called public attention to the
hazards of nuclear fission and asked for
a moratorium 'on the construction of new
plants and stringent operating controls on
existing ones. The division of opinion in
the scientific community about a matter
of such moment is deeply disturbing to
an outsider.
No doubt there are some additional
surprises ahead when other parts of the
fuel cycle become more active, particu-
larly in transportation of spent fuel ele-
ments and in fuel reprocessing facilities.
As yet, there has been essentially no
commercial experience in recycling the
Plutonium produced in nuclear reactors
. . Plutonium is one ot the deadliest
substances known to man. The inhalation
of a millionth of a gram — the size of a
gram of pollen - appears to be sufficient
to cause lung cancer.
Although it is well known in the nu-
clear community, perhaps the general
public is unaware of the magnitude of the
disaster which would occur in the event
of a severe accident at a nuclear facility
. . . With breeder reactors, the accidental
release of plutonium may be of greater
consequence than the release of the more
volatile fission products ... In addition
to a great variety of other radioactive
substances, breeders will contain one, or
more, tons of plutonium.
While the fraction that could be re-
leased following a credible accident is
extremely uncertain, it is clear that the
release of only a small percentage of this
inventory would be equivalent to the re-
lease of all the volatile fission products in
one of today's nuclear plants. Once lost
to the environment, the plutonium not in-
gested by people in the first few hours
following an accident would be around to
take its toll for generations to come - for
tens of thousands of years.
When one factors in the possibility of
sabotage and warfare, where power plants
are prime targets not just in the United
States but also in less developed countries
now striving to establish a nuclear in-
dustry, then there is almost no limit to
the size of the catastrophe one can
envisage.
It is argued that the probabilities of
such disastrous events are so low that
these events fall into the negligible risk
category. Perhaps so, but do we really
know this' Recent unexpected events
raise doubts. How, for example, does one
calculate the actions of a fanatical terror-
ist'
-------
I he use ol plutomum as an article
of commerce and the presence of large
quantities of plutomum in the nuclear
fuel cycles also worries a number of in-
formed persons in another connection.
Plutonium is readily used in the produc-
tion of nuclear weapons, and govern-
ments, possibly even private parties, not
now having access to such weapons might
value it highly for this purpose. Although
an illicit market has not yet been estab-
lished, its value has been estimated to be
comparable to that of heroin (around
$5,000 per pound). A certain number of
people may be tempted to take great
risks to obtain it
Thus, a large-scale fission energy econ-
omy could madveitently contribute to
the proliferation of nuclear weapons
These might fall into the hands of coun-
tries with little to lose, or of madmen, of
whom we have seen several in high places
within recent memory.
In [an] excellent article (in Science
magazine), Alvm M. Wemberg emphasized
that part of the Faustian bargain is that
to use fission technology safely, society
must exercise great vigilance and the high-
est level of quality control, continuously
and indefinitely. As the fission energy
economy grows, many plants will be
built and operated in countries with com-
paratively low levels of technological
competence, and a greater propensity to
take risks. . . Moreover, even in countries
with high levels of technological compe-
tence, continued success can lead to re-
duced vigilance. . . .
Deeper moral questions also surround
the storage of high-level radioactive
wastes. Estimates of how long these
waste materials must be isolated from the
biosphere apparently contain ma|or ele-
ments of uncertainty, but current ones
seem to agree on "at least 200,000
years "... Furthermore, there is the po-
litical factor. An increasingly informed
and environmentally aware public is likely
to resist the location of a permanent
storage facility anywhere. . .
Primary emphasis is now being placed
upon the design of surface storage facil-
ities intended to last a hundred years or
so, while the search for a permanent site
continues. These surface storage sites
would require continuous monitoring and
management of a most sophisticated
kind
It seems clear that there are many
factors here which a benefit-cost analysis
can never capture in quantitative, com-
mensurable terms It also seems un-
realistic to claim that the nuclear fuel
cycle will not sometime, somewhere, ex-
perience ma|or unscheduled events. These
could range in magnitude from local
events, fike the fire at the Rocky Moun-
tain Arsenal, to an extreme disaster af-
fecting most of mankind.
Whether these hazards are worth in-
curring in view of the benefits achieved is
what Alvin Wemberg has referred to as a
trans-scientific question. As professional
specialists we can try to provide pertinent
information, but we cannot legitimately
make the decision, and it should not be
left in our hands.
One question I have not yet addressed
is whether it is in fact not already too
late. Have we already accumulated such a
store of high-level waste that further addi-
tions would only increase the risks mar-
ginally? While the present waste (primar-
ily from the military program plus the
Plutonium and highly enriched uranium
contained in bombs and military stock-
piles) is by no means insignificant, the
answer to the question appears to be no.
I am informed that the proiected high-
level waste to be accumulated from the
civilian nuclear power program will con-
tain more radioactivity than the military
waste by 1980 or shortly thereafter. By
2020 the radioactivity in the military
waste would represent only a small per-
centage of the total. Nevertheless, we are
already faced with a substantial long-term
waste disposal storage problem. Develop-
ment of a full-scale fission energy econ-
omy would add overwhelmingly to it. . .
What are the benefits? The main bene-
fit from near-term development of fission
power is the avoidance of certain environ-
mental impacts that would result from
alternative energy sources. In, addition,
fission energy may have a slight cost edge,
although this is somewhat controver-
sial
Another near-term benefit is that fis-
sion plants will contribute to our supply
during the energy "crisis" that lies ahead
for the next decade or so. One should
take note that this crisis was in part
caused by delays in getting fission plants
on the line. Also, there seems to be a
severe limitation in using nuclear plants
to deal with short-term phenomena. Their
lead time is half again as long as fossil fuel
plants — on the order of a decade
The long-term advantage of fission is
that once the breeder is developed we will
have a nearly limitless, although not
necessarily cheap, supply of energy. This
is very important but it does not neces-
sarily argue for a near-term introduction
of a full-scale fission economy. Coal sup-
plies are vast, at least adequate for a few
hundred years, and we are beginning to
learn more about how to cope with the
"known devils" of coal.
Oil shales and tar sands also are po-
tentially very large sources of energy, al-
though their exploitation will present
problems. Geothermal and solar sources
have hardly been considered, but look
promising . . One of the potential bene-
fits of solar energy is that its use does not
heat the planet. In the long term this may
be very important.
Fusion, of course, is the greatest long-
term hope. Recently, leaders of the U.S.
fusion research effort announced that a
fusion demonstration reactor by the mid-
1990s is now considered possible. Al-
though there is a risk that the fusion op-
tion may never be achieved, its promise
is so great that it merits a truly national
research and development commitment.
A strategy that I feel merits sober,
if not prayerful, consideration, h to phzse
out the present set of fission reactors, put
large amounts of resources into dealing
with the environmental probiems of fossil
fuels, and price energy at its full social
cost, which will help to limit demand
growth.
Possibly it would also turn out to be
desirable to use a limited number of fis-
sion reactors to burn out the present
stocks of plutonium and thereby trans-
form them into less hazardous substances.
At the same time, the vast scientific re-
sources that have developed around our
fission program could be turned to work
on fusion, deep geothermal, solar, and
other large energy supply sources, while
continuing research on various styles of
breeders. It seems quite possible that this
program would result in the displacement
of fission as the preferred technology for
electricity production within a few dec-
ades.
Despite the extra costs we might have
incurred, we would then have reduced the
possibility of large-scale energy-associated
nuclear disaster in our time and would
be leaving a much smaller legacy of "per-
manent" hazard. On the other hand, we
would probably have to suffer the pre-
sence of more short-lived undesirable
substances in the environment in the
near term.
This strategy might fail to turn up an
abundant clean source of energy in the
long term. In that event, we would still
have fission at hand as a developed tech-
nological standby, and the ethical validity
of using it would then perhaps appear in
quite a different light.
We are concerned with issues of great
moment. Benefit-cost analysis can supply
useful inputs to the political process for
making policy decisions, but it cannot
begin to provide a complete answer,
especially to questions with such far-
reaching implications for society. The
issues should be aired fully and com-
pletely before a committee of Congress
having broad policy responsibilities. An
explicit decision should then be made by
the entire Congress as to whether the
risks are worth the benefits.
Reprinted by EARS
Environmental Action Reprint Service
University of Colorado at Denver
1100-14th Street
Denver, Colorado 80202
-------
Amateur A-Bomb?
The carefully written note contained
a message that was frightening/? clear.
Unless city officials paid the letter vrit-
fv $] •» -'[Hen nnd assured htm sc/r- pas-
sage out of the country, he would set off
an H-bomb in the middle of town. To
make matters worse, the note was ac-
f.cm^v»>'"?d t>v c tv>;/ '/" ^r//."^ dia-
gram of a thermonuclear weapon. Con-
sulted by city officials, experts at the
Atonac Energy Commission refused in
.'•^/;..' ceri'.t*n *•<',' ' ,'Ve v>o:ilo-be homo
e: '».£.'.-.• rtr '\*Wy a\i>cible of >;nryini, an'
his threat
This melodramatic incident A as rof
conjmsU up by a TV scriptwriter of a
science-fiction novelist. It actually oc-
curred m Orlando, Fla, a few years
ago. Only competent police work and
a slip-up by the "bomber" revealed that
he was in fact a 14-year-old high school
honors student in science who was bent
on nothing more than a spectacular
hoax. What made the mischief so chill-
ing was that nuclear blackmail by ter-
rorist or criminal organizations is fat
from inconceivable. It is quite possible
that a simple but devastating atomic
weapon could now be made by one or
more terrorists without advanced sci-
entific and technical skills.
That is the conclusion of a grow-
ing number of nuclear experts A re-
port prepared for the Atomic Energy
Commission and released last week by
the Senate Subcommittee on Executive
Reorganization labels the nation's safe-
guards against nuclear theft and black-
mail as "entirely inadequate to meet
the threat." A study conducted foi the
Ford Foundation by Atomic Physicist
Theodore B. Taylor and Arms Control
Expert Mason Willrich makes the point
even more strongly. In "Nuclear Theft
Risks and Safeguards," Taylor and Will-
rich report that amateur bombmakers
could probably put together weapons
as small as one-tenth of a kiloton (equiv-
alent to the explosive force of 100 tons
of TNT). Such bombs, says Taylor, would
be powerful enough to topple the twin
towers of Manhattan's 110-story World
Trade Center cr destroy the U.S. Cap-
itol building.
Greatest Deterrent. Physicist
Taylor's warning has not been lightly
taken; his credentials are impressive.
During his seven years at the AEC'S
Los Alamos Scientific Laboratory, he
specialized in the design of compact
and efficient A-bombs. Though Taylor
admits that the faorication of such de-
vices is beyond the capability of base-
ment bombsirjths, he feels chat tne man-
ufacture of less sophisticated and
powerful weapons is not
L'ntil recently, the greatest deterrent
to amateur bombmaking was the scar-
city of the key ingredient. Both weap-
QucjL tocQao/v o/t\u dou&tb Uj&o rrrvou Kivoc aQxxj&
uo hOAX}ruc\ a hij(AA(X»n QiOnrA^, JKaNiibo.'
Q # 0 Q *
UL uMJLK itKxo xJduU/x. \J6U aH^&mfixA am
rrr\ft.,
ons and nuclear reactors need fission-
aH.' iiiatetiii! to su^tai'i a chair ir.ai.tion
- -the familiar energy-producing process
in which tiny, fast-moving neutrons re-
leased by the breakup (fission) of one
iirc'tiblo atom smash into the nuclei of
neighboring atoms, causing them to
split The common reactor fuel—which
was also used in the bomb that leveled
Hiroshima—is a fissionable isotope of
uranium called U-235 But U-235 ac-
counts for only about one out of every
140 atoms of uranium in nature, and it
takes enormously sophisticated methods
to separate even a small amount of the
isotope from the more common, non-
fissionable uranium 238 Most of to-
day s so-called light-water reactors run
on a mix of only 3'7C U-235, which is
far below the enrichment level needed
by weapons makers In the future, plu-
tomum, which is far more efficient—and
lethal—will largely replace U-235 as
reactor fuel.
Easy Hijacking. The first man-
made element ever to be manufactured
in a quantity large enough to be seen
with the naked eye, plutomum was used
in the more devastating A-bomb
dropped on Nagasaki It is also a nat-
ural byproduct of the 20th century al-
chemy that occurs inside all nuclear re-
actors using uranium. But plutonium is
difficult (and thus expensive) to handle;
it is so toxic that the inhalation of only
a few specks of dust is sufficient to cause
cancer
Until recently, there has been little
peaceful use for plutonium, and most of
the small amounts produced by utility
companies has been either stockpiled or
used for research. But as methods for
using this material are perfected, plu-
tonium will become an increasingly
common reactor fuel As a result, traf-
fic in the stuff will swell. It will be
shipped from processing plants to fab-
ricating plants (where it is made into
fuel rods that are unusable for weap-
ons), to nuclear installations, and then
back again ior reprocessing In addition,
the Atc's highly touied "breeders.' a
new generation of reactors that produce
considerable amounts of plutonium, will
increase the "pioot" supply According
to ';ome estimates, by the year 2000 the
annual pioduction of p! utomuTi in the
U S will be 600,000 Ibs—and most of
thu will be in commercial rather than
Government hands
NUCLEUS Of A NUCLEAR HOAX
With so much of the material
around, terrorists might not find it too
difficult to get their hands on it Hijack-
ing could be relatively easy even though
shipments aie accompanied by armed
guards The AEC is tightening its secu-
rity measures against theft, but some
weapons-grade material is lost during
processing and merely written off as
MUF (materials unaccounted for). If an
employee-conspirator decided to accu-
mulate a critical amount of plutonium
by helping himself to a little MUF at a
time, the loss; might never be detected
Weapons-grade material could also be
taken by force in a dnect assault on a
storage fabrication or reprocessing
plant Though protected by fences.
electronic devices and armed gu.irds,
the plants are still far from impreg-
nable Last tall, for instance, the Gov-
ernment Accounting Office showed two
-------
511
of these buildings to be security night-
mares. Among its findings: doors with-
out alarms, gaps under fences, flimsy
sheet-metal walls, plastic skylights that
could be opened in one minute. They
also found inadequate liaison with local
authorities: when police were alerted in
one test, they went to the wrong loca-
tion 14 miles a way
Easier Than Heroin. Taylor, for
one, is convinced that terrorists could ac-
tually fashion the stolen material into a
bomb in a matter of weeks. To achieve
the biggest bang, the bombmakers
would probably choose to convert their
purloined material into a metal. Pluto-
nium and U-235 can be transported as
compounds that do not readily lend
themselves to the making of the most ef-
ficient weapons, but the techniques for
purification are, says Taylor, in some re-
spects no more difficult than refining
heroin in an illicit laboratory.
As for the actual manufacture of the
bomb, the basic information can be
gleaned from any number of public doc-
uments, some of them published by the
AEC. Essentially, all that is needed to
achieve a blast is to bring together a suf-
ficient amount of properly shaped fis-
sionable material fast enough to initiate
i massive chain reaction. To do that,
the Hiroshima bomb used the so-called
gun-barrel technique: both ends of a
heavy metal pipe were stuffed with
U-235 and the charge at one end was
used as a projectile. To detonate the
bomb, the U-235 projectile was hurled
by conventional explosives down the
barrel and into the mass at the other
end. The density of the material in the
combined masses of U-235 suddenly in-
creased enough so that the fast-moving
neutrons triggered a chain reaction and
the bomb exploded. The Nagasaki bomb
used a more efficient method: a hollow
sphere of plutonium was enclosed by
shaped explosive charges When the ex-
plosive was detonated, it sent much of
its force inward, crushing the plutonium
into a solid ball, a "supercritical" mass
that released even more energy than the
Hiroshima bomb. With the proper ex-
plosive and some plutonium fashioned
into the proper shape, a skilled ama-
teur might well produce a powerful
weapon.
To keep such potentially murderous
materials out of the wrong hands, the
AEC study recommends the establish-
ment of a federal nuclear protection and
transportation service, stronger links be-
tween the AEC and such intelligence-
gathering agencies as the CIA and FBI,
and tougher testing of the security mea-
sures taken by such "nuclear licensees"
as fabricators, processors and storage de-
pots. These measures could make it
more difficult for do-it-yourself bombers.
But perhaps no system is proof against
Murphy's Law, which holds that if any-
thing can possibly go wrong, it will Back
in the early 1950s, a routine inventory
revealed that a U.S A-bomb was miss-
ing, and no amount of searching suc-
ceeded in locating it As the military
sweated, a senior officer happened to vis-
it a dump on a military base He strolled
between piles of discarded A-bomb cas-
ings that were about to be offered for
sale as scrap. There among the rejects
he found the missing bomb
Bomb Designer's Warning Ignored
by Government 'Regulators'
NEW YORK (UPI) - Any reasonably
intelligent person can build a nuclear
bomb, claims physicist Theodore Taylor
who helped design much of America's
atomic arsenal.
With a do-it-yourself bomb guide drawn
from publicly available federal govern-
ment documents or local library, you can
buy much of what you need from the
hardware store and steal the rest - like
radioactive materials — from a nuclear
facility, according to Taylor.
The homemade nuclear bomb is what
Taylor has been warning the U.S. govern-
ment about for a year.
CONSULTANT
Taylor, 48, designed nuclear weapons
at Los Alamos, N.M. — near where the
world's first atomic bomb was exploded
- from 1949 to 1957 and has served as a
consultant on nuclear physics for the fed-
era! government and private industry.
Taylor said in an interview and an
article in a recent issue of "The New
Yorker" he first talked to the Atomic
Energy Commission and government offi-
cials about homemade bombs in 1967,
but was unable to convince anyone of
the threat
In the past few years he has tried to
bring the problem to the public's atten-
tion "until pressure forces the AEC to
stop pushing security under the rug."
According to Taylor, two things are
needed to build a crude nuclear bomb:
fissile (fissionable material) and know
how.
Enough know-how, he said, is available
in declassified documents and standard
reference works.
"The Encyclopedia Americana is very
good and so is the World Book," he said.
"Los Alamos Primer No. 1, used to brief
scientists in the 40's, costs $2.06 and is
available from the Oakridge Technical
Information Service."
Most other needed information, all but
the "gory classified details," is catalogued
in an annual publication,"NuclearScience
Abstracts," available in many libraries,
he said.
'STANDARD SOURCE'
"Anything else you need can be fig-
ured out from the declassified material
and standard sources," he said.
Taylor said the only barrier to home
construction of nuclear bombs is the
availability of fissile material, plutonium
or uranium. By 1978, energy demands
should begin to cause dramatic increases
in existing quantities of both, he said.
"All reactors either make or use plu-
tonium or uranium," he said. "Fast
breeder reactors make more plutonium
than they use."
Reprinted by EARS, Environmental Ac-
tion Reprint Service, University of Colo-
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Denver, Colorado 80202. Phone (303)
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Ctlif
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from Hm York
Co-Crttirmen
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Prof, of Mttfittnttia,
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Forrmr U S Attomty
Gtnertl
John T. Edttll
frol of Biochtmittry,
Harvard Univfnify
Paul R. Ehrlidi
Prof of Biology,
Stmford Umvertity
Owid R. Inoln
Prof ofPhyiia,
Univfnity of
Richtrd MM McCarthy
Former U.S.
Congnurrmn
from Nfw York
UnMcHarg
Chtirmin, Dtptrtmnn
of L»ndtc*pt
Archittctvn A fftgfomf
Pttnnine, Univmlty
of Ptnraylnnii
Lwvtf Muinfofd
Honortry FtllOH
Scitnet Policy Foundation
Lima Pauling
Moofl Lturmu
Prof. ofCtttmntry,
Sunford Univtnity
HaroMUrty
Mob*/ Lturtttt
Univfnity Prof.
fmtritui, Cntmntry
Ofpt-. Unntnityof
Ctlifornit a Stn Oitgo
G*orgtMMd
NoMLmnttt
Higgint Prof, of Biology.
Hfntrd Unnmity
Nobtl Ltunttt
Prof, of Biology,
Hfnsrd Unlvtnlty
A Sunshine Future
or a Radioactive One ?
by Egan O'Connor
On March 7,1973, the Atomic Energy
Commission issued its revised forecast of
nuclear power growth to the year 2000;
the forecast omitted the most important
figures of all.
In December 1972, President Nixon's
Solar Energy Panel issued an 85-page re-
port called Solar Energy as a National
Energy Resource; few people even know
about the report, although it is packed
with good news.
While the Solar Energy Panel says
there are no technical barriers to using
solar power, the cleanest possible source
of energy, the AEC forecast means the
U.S. is planning to use the dirtiest pos-
sible process.
THE NUCLEAR FORECAST
The AEC is predicting that nuclear
fission will provide about 30% of the
country's total energy in-put in the year
2000; in comparison, fission's contribu-
tion in 1972 was less than 1%.
Put another way, the AEC predicts
that atomic power plants in this country
will have a generating capacity of 1,200,-
000 electrical megawatts in the year 2000,
which is the equivalent of 1,200 atomic
power plants each with a capability of
1,000 megawatts. Atomic generating ca-
pacity in 1972 was 14,700 electrical
megawatts, distributed unevenly among
29 relatively small plants. Many states
today have no atomic power plants at all,
but by the year 2000, there could be an
average of 24 plants in each and every
state.
The figures of interest which do not
appear in the AEC forecast appear below:
During the year 2000, the forecast
1,200 atomic power plants would create
as much strontium-90 and other long-
lived radioactive poisons as the fissioning
of about 1,200,000 Hiroshima bombs,
plus at least 600,000 pounds of radio-
active plutonium (more, if there are
breeder reactors in operation). During the
following year (2001), the same plants
would add the same amount of poison
to the legacy again, and so on year after
year.
Is it possible to imagine a filthier pro-
cess than nuclear fission? It is the only
process for making power which creates
pollutants so terrible that they must
somehow be kept contained continuously
for 100,000 years.
According to the AEC forecast, it
would not be just made-in-America poi-
sons which would have to be kept out of
the environment and the hands of terror-
ists for centuries. The AEC predicts that
"other non-Communist countries" will
have 1,460,000 megawatts of nuclear
power by the year 2000, and "the Com-
munist countries" will have 600,000 nu-
clear megawatts by that time.
So, the combined production of long-
lived radioactivity in the year 2000 would
be the equivalent of exploding about three
million Hiroshima atom bombs per year.
It takes a special sort of mentality to
publish forecasts of nuclear growth with-
out a hint of its necessary twin - the
stupendous growth of radioactive poison
on this planet.
SOLAR ENERGY PROSPECTS
The fact is that we could have a sun-
shine future instead of a radioactive one.
In January 1972, the White House in-
structed the National Science Foundation
(NSF) and N.A.S.A. to organize a Solar
Energy Panel to assess the potential of
solar energy; nearly 40 experts were ap-
pointed from the fields of solid state
physics, chemistry, microbiology, power
engineering, architecture, photovoltaics,
thermodynamics, economics, sociology,
and environment.
-------
The following ten statements are quot-
ed from their report, Solar Energy as a
National Resource, December 1972:
1. Solar energy "is an inexhaustible
source of enormous amounts of clean
energy."
2. "In principle, solar energy can be
used for any energy need now being met
by conventional fuels."
3. "There are numerous conversion
methods by which solar energy can be
utilized for heat and power, e.g. thermal,
photosynthesis, bioconversion, photovol-
taic*, winds, and ocean temperature dif-
ferences."
4. From sea-thermal energy alone, "the
total annual production could exceed the
year 2000 projected total energy de-
mands."
5. "In 1969, the total electric energy
consumed in the U.S. could have been
supplied by the solar energy incident on
0.14% of the U.S. land area," a statement
based on U.S. average solar incidence and
the assumption of a 10% conversion
efficiency.
6. "There are no technical barriers to
wide application of solar energy to meet
U.S. needs."
7. "For most applications, the cost of
converting solar energy to useful forms of
energy is now higher than conventional
sources, but due to increasing prices of
conventional fuels and increasing con-
straints on their use, it will become
competitive in the near future."
8. With support behind solar energy
programs, "building heating could reach
public use within 5 years, building cooling
in 6 to 10 years, synthetic fucS from
organic materials in 5 to 8 years, and elec-
tricity production in 10 to 15 years."
9. "Solar energy utilization on a large
scale could have a minimal impact on the
environment if properly planned."
10. "It appears that an objective alloca-
tion of R&D funds would call for sub-
stantially increased R&D support for a
number of solar energy opportunities.
There are also international benefits in
making a viable solar energy technology
available to the world, as well as balance
of payments and national security bene-
fits in limiting our almost inevitable
dependence on foreign energy sources."
There is an eleventh statement which
is so significant that it must be saved for
separate consideration later in this report.
IS SOLAR POWER "ECONOMICALLY
COMPETITIVE" WITH NUCLEAR?
Obviously President Nixon ignored the
Panel's budget recommendations. Why is
the President such a powerful advocate of
radioactivity instead of sunshine?
513
FEDERAL BUDGETS FOR
NUCLEAR AND SOLAR ENERGY
In January 1973, President Nixon submitted his Fiscal 1974
budget proposals lo Confess. for nuclear and solar energy, the
figures are approximately as follows:
Nuclear fission: civilian reactor technology $456,000,000
Nuclear fission: regulation 54,500,000
Nuclear fission: AEC bio medic.il and environmental
research (at least half ol the $99 million
budget should be attributed to the prin-
cipal cause of concern atomic power
plants 49,500,000
Nuclear fission: public relation* (est.)
nuclear science demonstrations
and exhibit-. 1,100,000
semi-technical films, press releases,
speeches 250,000
Other information services, $5 million;
includes some highly technical ones
which .lie not public relations 2,000,000
(est.)
Peaceful nuclear explosions ("Plowshare")
the use of nuclear bombs to stimulate
natural gas production* 3,800,000
Nuclear fusion: including military research 70,000,000
Solar energy: National Science Foundation 12,200,000
NASA space power work, $6.4 million;
assume some transfer to earth-systems 3,200,000
(est)
*Plowshare is discussed later in this report.
TOTAL FOR FISSION:
TOTAL FOR SOLAR:
Approx. $563 million
Approx. $ 15 million
How does Nixon's $12 million for solar energy (on earth)
compare with the budget recommendations of his Solar Energy Panel?
For a 15-year solar R&D program, the Panel made the recom-
mendations below:
Thermal energy for buildings $100,000,000
Renewable clean fuel sources:
Photosynthetic production of organic
materials and hydrogen 60,000,000
Conversion of organic materials
to fuels or energy 310,000,000
Electric power generation:
Solar thermal conversion 1,130,000,000
Photovoltaic conversion (solar cells) 780,000,000
Wind energy conversion 610,000,000
Ocean thermal differences 530,000,000
Seven additional tables in Appendix A indicate that the Panel
recommended $153 million be spent over the next few years
to fund work which is ready to commence right now
-------
514,
If popularity were a consideration,
safe and natural solai power systems
would almost certainly be more popular
than plants each holding 1,000 Hiroshima-
bombs of radioactivity.
If technical feasibility were the crite-
rion, solar power would also have the
advantage over nuclear fission; both, how-
ever, are ceitain to deliver usable energy.
This certainly distinguishes them from
controlled nuclear fusion, whose control
has not quite been achieved yet.
Can the President claim that nuclear
fission will be cheaper than solar power7
Let's look at some figures.
The Federal Government has already
spent over three billion tax-dollars devel-
oping civilian nuclear power. Out of $456
million for reactor technology in the
Fiscal 1974 budget, $320 million is for
developing the breeder reactor, a power
reactor which produces even more radio-
active plutonium than today's nuclear
power plants. The AFC expects to spend
about four billion tax-dollars |ust devel-
oping bleeders for commercial use by
1990
Whjt notifies this investment' The
Fermi K aitor 30 miJcs from Detroit,
Michigan, is the only commercial breeder
plant ever built in this country When the
plant was under construction in 1963,
the chairman of Detroit Edison predicted
that the plant would earn $92 million by
1970 from selling electricity to Detroit
and plutonium to the AEC But in 1966,
Fermi had a serious accident which took
about four years to repair Then there
was one problem after another
By mid-1972, the plant had run at full
power for about 30 days and produced
about $1 3 million worth of electricity,
and too little plutonium for the AEC to
buy Meanwhile, the cost of the Fermi
plant had swollen from $50 million to
about $ 130 million
On November 29, 1972, plans were
announced to shut down the Fermi plant
forever. Its total electric production was
about 32 million kilowatt-hours in its life-
time which means that Fermi's electri
city really cost $4.00 per kilowatt-hour.
In comparison, electricity normally sells
today to residential customers for about
3^ per kilowatt-hour
In short, our only experience with the
breeder so far shows it to be very far
from an economically competitive and
reliable source of powei From the com-
petitive point of view, as well as reliability,
solar power looks just as good or better •
'than the breeder.
There have been no commercial solar
power systems comparable to Fermi be-
cause none has been funded. The only
real experience we have with solar power
so far is from the space program, where
solar cells have been producing electricity
reliably for 12 years.
Solar cells happen to be the most
expensive solar technology at the mo-
ment, and yet experts say even the cells
would provide electricity at commercially
competitive prices if their cost were re-
duced about 100-fold. Almost everyone
who knows anything about solar cells is
confident that the cost-reduction can be
achieved in a few years, if a modest R&D
investment is made
In addition to solar cells, there are
several other solar energy technologies
which could quickly become econom-
ically competitive in the opinion of the
Solar Energy Panel.
For instance, one member of the
Panel, civil engineering professor William
Heronemus, testified at an AEC licensing
hearing in January 1973 that wind-power
(an indirect form of solar energy) could
provide as much electricity for Long
Island in 1977 as a proposed nuclear
power plant at the same cost or less,
and with much greater reliability
THE QUESTION OF CHEAPNESS
The question of cost deserves exam-
ination, whether it is the cost of energy,
the cost of saving tall trees in a future
housing development, the cost of pre-
ventive medicine, or the cost of organiz-
ing society's work in a way which might
stimulate, satisfy, and include more hu-
man beings.
The question, "But is it economical?" '
is asked invariably, but seldom does
anyone ask, "Is it what people would
like to have?"
"But is it economical?" is a funda-
mentally anti-human question when it
implies that cheapness is more important
than any other considerations. If nuclear
electricity cieates the possibility, even
the probability, of poisoning the planet
forever, is the cost of solar power the
most important issue to be raising?
THE ELEVENTH QUOTE
Let us review what the Solar Energy
Panel said about cost "For most ap-
plications . . it will become competitive
in the near future " About technical
feasibility. "No technical barriers." About
time-frames: commercial readiness within
5 to 1 5 years.
But then, without elaboration any-
where in the report's 85 pages, the
Panel made the following statement
which I called "the eleventh quote" ear-
lier:
By the year 2020, "solar energy
could economically provide up to
35% of the total building heating
and cooling load,
30% of the nation's gaseous fuel,
10% of the liquid fuel,
20% of the electric energy re-
quirements."
All the percentages - especially for
electricity - seem extremely low in
view of the Panel's other conclusions.
There is more than enough solar energy
available in this country to make all
the figures 100%, if the nation were
determined to have it so.
The great significance of the 11th
quote, in my opinion, is that it re-
flects political reality. Although solar
power makes sense in every way, it
is simply not wanted yet by the powers
who own this country's fossil fuel and
fission resources and equipment.
If you agree that these interests have
always set the country's "energy policy,"
you can easily understand how Nixon
could say in June 1971 that the nuclear
breeder is "our best hope for the future,"
and blurt out in September 1971 that,
"This business about breeder reactors
and nuclear energy is over my head."
Obviously someone else is making Nixon's
fission policy for him.
His concentration on nuclear and fos-
sil fuels matches perfectly the desires of
industr\ On March 12, 1973, the Amer-
ican Gas A-sn., the American Petroleum
Inst., the Atomic Industrial Forum, the
Edison Electric Institute, and the Na-
tional Coal Assn. issued a joint state-
ment about energy which called for a
strengthened commitment to research
and development in both nuclear and
fossil fuels. The Electric Research Coun-
cil is putting the lion's share of its
niggard research dollars into the nuclear
breeder, a little into fusion, and some
into fossil fuels; for solar energy there
is lip service.
In Congress, the situation is the same.
On Maich 19, 1973, a bill entitled
"The National Energy Research and De-
velopment Policy Act of 1973" was
introduced into the Senate. Its prime
sponsors (there were 28) included the
Senate's three most powerful energy fig-
ures: Senator Jackson, Chairman of the
Interior Ccmmittee and member of the
Joint Committee on Atomic Energy
(JCAE); Senator Magnuson, Chairman
of the Commerce Committee; and Sen-
ator Pastors, Vice-Chairman of the Joint
Committee on Atomic Energy.
The bill, S.I283, proposes to create
five energy development corporations —
four for tossil fuel and one for geo-
thermal energy. Obviously nuclear fission
already has all the government support
it can abscrb.
-------
f";li) i% and }('I'G ,-,.>,.'wo < ff\
oieiicies to1 c,olareneigy ^e feasible .vj '•
The efficiency of solar ent-g*. - i->'ersi(M
by ire;", and glass it; nari-'j' pcovsirf;,.'
ranges from 0.3% In 3 i>~V, algae with
very much higher effivicme' havi- reen
cultivated for jt least ! 3 y/(V"' j llic
Univetstly ut California anJ .jlct-v.'h -it
•\s tor !0% conversion efftcienry, thr
averagc ef:-,.ifn,,y of bolar cell- ' ti tsfr;
today is alieudy 1S«, with lfic/- ef
ficiency in if-air fahoidlory te'>fj. !•'
addition, conversion p'ficienciie* IP rtio
range of 20% - 30% ait e-q.ecud in trie
production <>" solar electnmv -lung the
heat-turf ine systen (eg., • thi Meinei
p'--iposal")
DEALING WITH BUShD REPORT*
People who ar" familiar with (.,'>(>
exaggeiated safety and economy claim;
of nuclear fi"ioi. experts should vie"'
goj'j nc\v\ from solar enerv uxpeit'
with SKfcp.iciim, .00
hie »,ountry(s R&U S'/stf'1 ss ^:>i!/ed
TO that exr>tii< m any flelc dltflo r a I
w,3*r, nave -i vf.',rr' ,/uerr^1 in prornoJ -ig
that fie.U. "(Here are virfu.-Jiy no i tperu
witho " a • ion ut'-jtij1 hi is suvi ex
pert' 'Ah, au- withal get t>'-
ing iecor?ifPCii iation
'It .> mipoiM'ii that a polity
cf tesc.irch and review for eruirop-
menijl ef'ci:t>> be made > .jil^gtal
pa;t 'if ti'e R&D process, ("an-
tinuoi/- teedbaci i»!o tht dew-
>oniti'f piogia'n i-> crstu.iiiy ini-
porunt to prtvent t'ot- undue
expfriduure d funds for r^ocesses
that coulJ uitirraii'l'/ prove un-
accfKtablt from a public point of
view. One of the Tiajor obstacles
tc public acceptance of nuw IfcC^-
:.ologies ii the *ear th?t cliero are
unknown side effects thai have no;
i'oen adt'uaately investigattf or
disilosed."
it is tefresh ng ihat someone thinki
what the public wants srould count,
and lhat truth has an intrinsic value
no mattet whtre the chips fall.
Ms Egan O'Connor
Ai for solar ene'gv, the bill wo.ild
leave its fate right in the hands ot the
very people who have been ignoring
it for the last seveidl '.ears. The bill
proposes that "a compiehensive energy
research and development strategy for
the Federal Government" be determined
by a committee composed of an Assistant
Secretary of Interior, a Commisvoner
of the AEC, a Commissioner of the
Federal Power Commission, the Director
of the Natiorai Sc.ence Foundation, an
Assistant Administrator of N.A.S.A. and
"rfcpiesenU'i-'es of other executive agen-
cies whkh the President finds have a
significant and continuing 'ole in energy
R&D " The thairnian •; < r'-'is committee
is to be appointed by the President, too.
A FUTURE WITHOUT SUNSHINE
Unless new forces (grass-roots aiid
industrial) can organize powerful sup-
port for solai en< rg/ s^ 3:cms, we just
won't have any. We wih r ave a grotesque
expansion in fossil fuels and fiss'on. There
is even a unique combination in the
works - the stimulaiion of nali-ral gas
fields by the underground c/plos.on ot
nuclear Don'Ds
The pio.'iam lo promote the peaceful
use of atomic bomhs ,' railed "Plow-
share." The "fcc has -iiif-ady produced
some radioactive ridi'jial gas, with the
help of industry, in New Mexico and
Culoiado A tn', i Wowshare "exper
iment" is scr
5 How to yet tiie full report o*
*fi« Solar Energy Panel: Only 3,000
cooies were printed ,»nd most are gone;
a few remain. Conlact Dr. Frederick
Morse, Dept. Mech. Engineering, Univer-
sity of Mar>'! an. I College Park, MD
20742.
Reprinted Dy EA RS
Envwoniri^'ial Action Reprint Service
University of Colorado it Denver
MOO 14th Street
Liciivet. Colorado 80202
Phone (303) S34-S6'!2
Distributed by:
This paper contains 70% recycled fibers - Environmental Action Reprint Service
-------
-------
517
Chairman Mills: The next speaker on my agenda, Mr.
Geichman, has left, and he will submit a written statement.
Mr. Lehrburger from People for Rational Energy Sources.
Is that correct?
-------
-------
519
TESTIMONY PREPARED FOR
U.S. ENVIRONMENTAL PROTECTION AGENCY
LIMITATION OF ENVIRONMENTAL CONTAMINATION
BY PLUTONIUM AND THE TRANSURANIUM ELEMENTS
January 10, 1975
By
Carl Lehrburger
70 Adams
Denver, Colorado, 80206
Mr. Lehrburger is a representative of
PEOPLE FOR RATIONAL ENERGY SOURCES (PRES)
-------
520
Good day. My name Is Carl Lehrburger, and I am a representative of
People _for Rational Energy Sources (PRES). I have been working the last
three years in the areas of public education on energy policy and energy
alternatives to nuclear and fossil fuels. I am currently employed with a
solar energy research and development firm.
In establishing standards limiting environmental contamination by
plutonium and other transuranium elements, disassociating radiation
contamination of the environment from the nuclear industry and the social
applications of these elements will seriously misinterpert the problems
that confronts us. In setting plutonium standards, it is my contention
that the Environmental Protection Agency consider the social implications
of the proposed plutonium economy and the decision to undertake plutonium
recycling.Cn'-/fy re^ln-hn^ He s<"A_r5f-> °^ P'wf**"«*i «n4. lwan-tn&ei< t«ei«o toucleictf
to,;/ fin? tTP°A. t>e c.iyi-e -^ <-
-------
521
Dr. Alvin Weinberg, former Director of the Oak Ridge National
Laboratory has written:
". . . The discovery of the bomb has imposed an additional demand
on our social institutions. It has called forth (this) a military
pristhood upon which in a way we all depend for our survival.
It seems to me that peaceful nuclear energy probably will make
demands of the same sort on our society, and possibly of even
longer duration." _
Writting on the same subject, Tamplin and Cochran have written:
". . .We suggest that it is beyond human capability to develop
a cadre of sufficient size and expertise that can be counted upon
to understand nuclear technology, to control it, and to prevent
accidents and diversions over many generations", f.n.
With or without the existance of plutonium standards over environ-
mental pollution, contamination to our world is inevitable, unless we
begin regulating the amount of plutonium and other transuranium elements
in use at any one time and the use that they are applied to.
If the proliferation of nuclear power continues, increased accidents
can be anticipated in the production of electricity and in the trans-
portation, reprocessing and storage of radioactive materials. The
track record of the nuclear industry demonstrates that accidents are
unavoidable. Major nuclear reactor accidents have already occurred at
the Fermi experimental "breeder" reactor near Detroit and at Windscale,
England, where large land areas were contaminated. A 1973 AEC Task
Force Report disclosed approximately 850 "adnormal occurrences" at nuclear
reactors over a 17 month period.
The proliferation of nuclear power to foreign countries means that
nuclear bomb-grade materials will be diverted to make nuclear weapons, as
India's "peaceful" nuclear detonation demonstrates. Even though the United
States publically gives lip service to nuclear disarmament, the U.S.
nuclear industry is the largest producer and promoter of nuclear weapons
and nuclear reators in the world. Exporting nuclear reactors to other
nations can only work against disarmament and world peace by giving them
the opportunity to build atom bombs. By 1980, 29 countries could have 231
nuclear power reactors, many being supplied by U.S. nuclear corporations.
Will standards established for permissable amounts of plutonium
in the environment have any significant effect in avoiding contamination,
directly or indirectly, in these 29 countries, which would invariably
mean radiation contamination throughout the world? Probrobly they would
have no more success then the United States attempts at nuclear disarmament
and world peace. The contridiction remains: The U.S. cannot have disarm-
ament if it engages in the sale of weapons, just as an environment free
from radiation pollution is impossible to achieve if we continue expanding
our nuclear industry.
f.n. "Plutonium Recycle or Civil Liberties: w« can't have both" Environmental
Action, Dec. 7, 1975
-------
5-22
page 3
Plutonium is modern man's "death wish". Something so devious, so
powerful and so long-lived as plutonium has captured the attention and
imagination of our technological "pristhood", for they desire the
longevity of their creations. It is well known that plutonium was
named after Pluto, the Greek's Lord of Death, and that plutonium is a
major substance for producing atomic weapons. Today, sectors of the nuclear
industry and the AEG advise IB that a "plutonium economy" is the solution
to our energy and nuclear waste "disposal" problems. They realize that
using plutonium as a fuel for nuclear reactors can immortalize their
technology and their profits. For the rest of us and future generations,
we will be bound to safeguarding ourselves from this hidious creation ®€
of men for thousands of years, just as we have been beplagued by Pandora's
curiosity. Let us not forget the symbolic meaning, or else we may loose
sight of the underlying moral significance of what we came here to discuss.
Unless we begin regulating the source of plutonium and manmade
radiation, there will never be an environment free from contamination.
We as a race must take control over our technological creations and the
elite that uses them for personal power and profits, or else fall pray to
our technology, which will shape us, rule us and finally destroy us.
This ultimately means limiting the use of and the amount of plutonium
and transuranium elements in society. To do less is to avoid our social
responsibiltiy to future generations.
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Thank you.
Chairman Mills: Thank you very much. Are there any
questions?
(No response.)
Chairman Mills: Again, thank you very much.
The next speaker on the agenda is Ms. Nina Conant from
St. Mary's Episcopal Church.
Ms. Conant: Learned Gentlemen and Fellow Citizens:
I have here some statements that represent the humanis-
tic point of view. They are statements of sort of average
citizens. It was impossible to contact the entire member-
ship of St. Mary's Episcopal Church at 2290 South Clayton.
However, the priest, vestry members, and laymen thus far
contacted subscribed to the following resolution:
"We urge utmost caution and continuing study by highly
qualified scientists to assure protection of the present and
future populous from injury through atomic radiation or any
noxious product thereof."
The next statement is one subscribed to by 38 individ-
uals, and it reads as follows:
"The AEC has not effectively protected our environment.
One example being the radioactive tailings found in some
Grand Junction houses. In the absence of probable fact as
to harmful radiation levels, we therefore urge more strin-
gent standards be imposed at this time for nuclear weapons
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524
facilities and nuclear reactors than have been established
in the past."
And the last is a plea from one citizen, me, to you in
behalf of the human race.
"Gentlemen, if mankind becomes extinct on this planet,
it will not probably be through terrible wars, plagues, or
catastrophic explosions. No. Much more likely it will be
through rushing to embrase marvelous discoveries that seem
to make our daily lives more pleasant, convenient, and
comfortable. We will not recognize the lethal side effects
until it is already too late. We are even now flirting with
such a course. For the first time in the history of the
world, man's future fate is in the hands of a living gen-
eration. We must face this fact with a new and more difficult
morality. We are not only our brother's keeper, but espe-
cially the protector of children yet unborn."
There are three points here, two of them relate to this
body, and the third does not, but I will read it anyway,
with your permission.
"We must not for any reason proceed on any course of
investigation and manufacture where there is a known risk,
however slight, of producing defective children."
And the second one: "We must stop rescuing and sub-
sidizing famine-stricken populations whose birth rate over-
runs and devastates their own land resources. By supplying
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525
them with emergency food, we ultimately compound their
misery, like the man who could not bear to hurt the puppy,
so he cut off his tail an inch at a time."
The third one again relates to you: "We must cure our
voracious appetite and stop opening up greater and greater
wasteful sources of energy. Rather, we must find ways of
utilizing more wisely resources that we already have."
Gentlemen, the foregoing sounds all very simple-minded
and self-evident. However, we have not yet accepted this
kind of morality, and we must hasten to do so if we are to
get off the collision course upon which we have already
embarked.
Thank you.
Chairman Mills: Thank you very much. Are there any
questions or comments?
(No response.)
Chairman Mills: Thank you again.
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Mr. Mark Tryen of South High School here in Denver.
Mr. Tryen: First I want to point out that my name is
Mike Tryen, and it is misspelled on the agenda.
Chairman Mills: We will correct it.
Mr. Tryen: Thank you. First of all I want to say that
I appreciate being able to make this statement on behalf of
my ecology class at South High School and the youth of
Denver.
The students and I have been taught some background
information about plutonium-239, a very toxic substance, and
we feel we should make a stand. Plutonium-239 is an element
used in manufacturing triggers for hydrogen devices, and as
an element it is one of the most toxic substances known to
man. According to the information we were able to find, and
I would like to point out that there is not a great deal of
information available concerning the chemical and biological
effects of this element immediately available to us, it is
20,000 times more toxic than cobra venom or cyanide and
1,000 times more toxic than heroin. It is a high-energy
alpha-emitter and is not necessarily dangerous externally,
but internally it will do a considerable amount of damage to
cells. In the lungs, the alpha emissions will probably
cause lung cancer.
Plutonoum-239 is listed on the radioactive nuclide
charts as having a half-life of 2.439 times 104 years or
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533
24,390 years. This means it will be highly radioactive for
this length of time before it decays to half its radioactivity.
This contamination, as far as all of us are concerned, is
permanent. Our ecology class feels that this problem is
being handed down to the next generation (which is us), not
necessarily you, and I am here to express our concern. If
we are going to let the older generation make decisions for
the future which will affect our lives, we feel we should
express our feelings also.
It would not take a very large quantity of this material,
airborne, to give everyone in Denver lung cancer eventually.
We feel its use must be restricted before a major disaster
occurs, and we then sit around and wait for the mortality
statistics to confirm our suspicions. In 1969 a fire did
occur even with strict supervision, and contamination was
released to the surrounding area. The public was unaware of
this for many years following this, and in the meantime some
of them were obviously building homes in the area not know-
ing what might be in the soil. Perhaps the supervision now
in use is not enough.
Some of the problems associated with contamination and
use of this material seems almost impossible to imagine.
Although strict controls are exercised there, it is still
the problem of the contamination already there. Increased
risk of lung cancer is only one -- what about genetic damage
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534
to future offspring of contaminated parents and shorter life
spans for children playing in contaminated dirt? If the
problem were not serious, they would not now have stopped
building homes in the area downwind of the Flats. Cows
grazing around this area have been found to have plutonium
in their lungs. How did this happen? We wonder about their
milk and meat also. Is this also contaminated? These
questions should be answered before any more plutonium is
used at the Flats. The contamination already there seems to
be finding its way into our environment in ways that were
not considered when Rocky Flats was built.
We feel that keeping Rocky Flats in Denver now makes
this area a strategic military target and exposes us to yet
another type of danger -- which is just as deadly as contami-
nation.
The first mistake was the placing of a plant such as
this in a populated area and we feel, since contamination
already exists, that there should be no minimum allowable
dosages for emissions established. There should be no_
allowable emissions and if there are, the manufacturing of
plutonium triggers here should be reconsidered.
I had one day in which to speak to my fellow students
about this matter and was able to get the signatures of 235
people who also expressed their concern. I will give you
this list and I am sure, had we had enough time, we would
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535
have had more signatures of people to support my stand.
I must stress this last point -- that I am here because
the students at South High do_ care enough about this problem
to send me here to represent them. The youth of Denver dp_
care.
Chairman Mills: Thank you very much. Are there any
questions or comments?
Dr. Taylor: I am especially interested when young
people, high school people, engage themseleves in thinking
of this type, activities of this type. I try whenever I
have the opportunity to help them when they ask for help. I
want to compliment this group on having put together some
ideas. They seem to have a fair amount of good information
and not much more than the normal amount of misinformation.
I would be very happy when I get back to try to supply them
with some sources for some of the kind of information that
might help you in thinking about some of these problems from
a purely technical sense. I hope also that some of you will
go into physics and biology as you grow older and pursue
these subjects in real earnest.
Mr. Tryen: Thank you very much.
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Chairman Mills: Mr. William Pace.
(No response.)
Chairman Mills: We have a few additional names that
might still be around. Mark Edwards?
(No response.)
Chairman Mills: Mr. Rick Speed.
Chairman Mills: Will you give your address?
Mr. Speed: 70 Adams, Denver, Colorado, 80206.
Hello, my name is Rick Speed. I have been active in
the energy resource field for several years, and presently
work for a solar energy research and development firm. I am
here today to share a few thoughts with you which I consider
to be the long-range, realistic solution to the dangers of
plutonium that have been amply documented today. In my
view, the two most overwhelming dangers that are presented
to us are radioactive contamination of the environment
through the improper use of nuclear power, and thermonuclear
war. Prudent and wise men everywhere now call for the
control of these elements, and it is my contention that it
should now be obvious that the only reasonable solution for
the genetic, health, social, and environmental problems
presented by these elements is their destruction, their
total destruction.
Fortunately, there are technologies capable of carrying
out this mandate and at the same time helping to alleviate
another of our major problems, the energy situation. If the
nuclear weapons nations, states, could agree on a formula to
eleminate their nuclear arsenals, the dangers of thermo-
nuclear annihilation would then be eliminated. The bomb
543
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544
grade materials would then become available and could be
diverted to nuclear burner reactors wherein the high grade
weapons material could be transmuted to high level nuclear
wastes. So, we would have solved several problems at once.
We would have generated electrical energy, and we would have
decreased the half-life of the materials that we had to
contend by several factors of ten, and we would have ended
up with materials of nowhere near the toxicity of plutonium.
We could carry on this whole process in underground nuclear
parks or whatever you will have as suggested by Drs. Teller
and Wienberg, where the latest in contaminant and plutonium
burn-up fuel cycles could be utilized to destroy these
materials. The electrical energy that we have been gen-
erating from these totally enclosed recycling units would
also eliminate the need to produce any more of our present
generation of reactors, and we could continue to burn up our
uranium-235 in low enrichment fuel cycles with their obvious
advantages from the security viewpoint. And, I think it is
also during this period when we were carrying out this
solution to the plutonium problem that we begin a massive
program in energy conservation and solar energy conversion
so that we can develop energy systems that are reasonable,
that are rational.
In conclusion, just let me say that I have looked at
this problem from a fairly comprehensive viewpoint, and it
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545
appears to me that this is the only real long-run solution
to the problem. We just cannot have plutonium and highly
enriched uranium-235 in the environment, or it is eventually
going to cause us grief, and I just hope that you and your
counterparts in Government industry realize this and work
for the ultimate destruction of these materials.
Thank you; any questions?
Chairman Mills: Thank you, any questions or comments?
(No response.)
Chairman Mills: Thank you again.
Melody Martin?
(No response.)
Chairman Mills: That seems to have exhausted the list
I have. Is there any comments that the Panel would like to
make in this regard? Yes?
Ms. Barbara Hanson: Those written questions that you
asked to be handed to the members of the Panel, are they
going to be addressed now?
Chairman Mills: I have two questions addressed to the
Panel.
One question: How will present studies being proposed
in Florida phosphate areas be coordinated with the present
hearings, especially plutonium? I assume this has reference
to the natural radioactivity in the phosphate mine, which is
mostly radium, and what we are talking about here is plu-
-------
tonium and the transuranium elements. But, EPA is, in fact,
addressing the phosphate problem.
Will the studies already in progress in Idaho Region X
be considered or will there be a lot of duplication of
different agencies, especially concerning plutonium? I am
not sure I really understand that question, whether they are
speaking of the phosphate industry in Idaho or plutonium.
But, certainly we will make every effort to try to avoid
duplication.
In other words, what about phosphate plutonium emission
regulations? I am not sure I really understand that ques-
tion. There is no plutonoium in the phosphates, that I am
aware of.
Second question: Judging from the remarks made by Mr.
Bean, the AEC representative at Rocky Flats and Assistant
Manager of Post-Operations there and his associates this
morning, we are led to the inference that the amounts of
plutonium leaving the plant at Rocky Flats are below stand-
ards or below estimated probable hazard levels. This is
based on measurements in air or soil of plutonium itself,
but no mention of plutonium in combination with other
chemical substances. For instance, the tritium, a radio-
active isotope which is used by the Rocky Flats Plant in
their development of thermonuclear tritium devices, and it
is this tritium (which apparently causes no harm by itself)
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547
acting on the plutonium which releases a highly toxic
substance which is released into the air, whose contami-
nation potential is there being much more difficult to
assess or control. Could you address this matter, please?
I assume what the question is, is there any kind of syner-
gistic action between the tritium releases and plutonium?
As far as I am aware that is not a very viable consideration
at the moment. When we look at standards for tritium or we
look at standards for plutonium, we treat them separately.
Maybe I missed the point of your question.
Ms. Barbara Hanson: I believe, from what I have been
told and the literature, they are treated separately. But,
I was given this information. In fact, there are some who
are pretty conservative on pro-nuclear weapons and when they
found out that I was interested in coming before this hearing,
they did not tell me any more. But, he did say that tritium
acts on the plutonium and it is the combination of the two
that creates a more dangerous or more toxic substance. It
is released into the air and it is harder to control and
harder to assess that amount in the air, and I was wondering
if you could give me a more technical explanation on that?
Chairman Mills: Well, I am not sure I really under-
stand the question. Any hazards associated with plutonium
or tritium by themseleves, one could --
Ms. Barbara Hanson: Don't they combine? Doesn't one
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548
act on another when they are used in combination?
Chairman Mills: Not to my knowledge.
Ms. Barbara Hanson: Well, apparently this is what goes
on at Rocky Flats, because he works in conjunction with
Rocky Flats, and this is what he said. I am sorry he is not
here. I was hoping somebody could give me some more infor-
mation on it.
Chairman Mills: Does anyone want to try to clarify
that? Maybe the concern is with the difference between
fussion and fission systems.
Mr. M. A. Thompson: Tritium is like hydrogen, and
hydrogen will react with plutonium, okay, chemically to make
a compound combination of the two. There is no work going
on at Rocky Flats involving tritium plus plutonium. Now,
when you talk about the hazard of the combination of these
two, you then assume the hazard of the tritium plus the
hazard of the plutonium.
Chairman Mills: There is no additional synergistic
action --
Mr. M. A. Thompson: No, the combination would not be
ten times as much as the addition of the two.
Ms. Barbara Hanson: You are saying one plus one equals
two, and I am saying one times one makes something else, and
you are saying that that is not going on at Rocky Flats?
Mr. M. A. Thompson: Correct.
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549
Ms. Barbara Hanson: You would not deceive me now,
would you?
Mr. M. A. Thompson: No.
Chairman Mills: I will allow one question if it is a
brief one. We are pretty tired.
(Question from the auidence) Is the EPA going to give
more public hearings, and if not, how do they plan to com-
municate with the public on issues that you did not consider
relevant to this public hearing, such as --
Chairman Mills: I assume you are talking about nuclear
safety --
(Question from the audience) How is the public going
to communicate with you about that?
Chairman Mills: Well, we in the EPA, and I am not
speaking now as part of the Panel, I am speaking of EPA, we
in EPA have been looking at some of the reports such as
Rasmussen, We have been reviewing the environmental impact
statements pertaining to these questions. Our review is all
part of the public record. So, we do, in fact, speak out on
these issues, and they are, in fact, part of the public
record. If you are interested on a particular question
pertaining to some particular interest that you have, I am
sure you can write to the Environmetal Protection Agency,
and they will send you a copy of their comments.
Mr. Wolfson: Does the EPA have the authority to call a
-------
nuclear moratorium and nuclear disarmament, or do they only
have the authority to set the standards and limits on radio-
activity?
Chairman Mills: Our authority is limited to the law,
which says setting generally applicable environmental stand-
ards .
Well, if there are no more comments by the Panel or the
audience, I want to thank all the participants. I hope it
has been informative. It has been informative to us, and I
am sure that we have built quite a record on the problem of
plutonium.
Thank you very much.
(Whereupon, at 6:00 o'clock p.m., the hearing in the
above-entitled matter was closed.)
«U.S. GOVERNMENT PRINTING OFFICE:1975 630-513/794 1-3
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