Hence the pertinence of the question whether building the proposed highway at Rocky Flats would endanger people by exposing them to plutonium. To answer this question, the Rocky Mountain Peace and Justice Center contracted with Marco Kaltofen of the Boston Chemical Data Corp. to collect soil samples in the area proposed for construction of the highway and to analyze the samples for plutonium content.

We asked the U.S. Fish & Wildlife Service, the agency that manages the wildlife refuge, to allow Kaltofen and his colleague, Strongbear, to enter the refuge to collect samples in the area intended for the highway. FWS denied this request. Thus, in September 2011 when Kaltofen and Strongbear came to Colorado they collected samples outside the refuge fence along Indiana St., route of the proposed highway. In this area they collected 19 samples from surface soil, plus 3 at a depth of 12 inches and 1 at a depth of 6 inches. Samples in which they detected plutonium were further analyzed for composition and the size of individual microscopic particles to identify those that represent a significant inhalation hazard.

Principal findings from soil samples

Kaltofen and Strongbear found that the Indiana St. study area was contaminated with plutonium and traces of americium. The plutonium concentrations in their samples were roughly equivalent to concentrations found in the same area in 1970 by P. W. Krey and E. P. Hardy of the Atomic Energy Commission (see Figure 1). According to Kaltofen, “There was no statistically significant difference between this data set and the 1970 data set. Plutonium losses appear to be approximately equal in magnitude to plutonium inputs [from upwind portions of the site] in the Indiana St. area.”

Figure 1: Plutonium distribution in soil in 1970; adaptation of a map prepared in that year by P. W. Krey and E. P. Hardy of the Atomic Energy Commission. The Rocky Flats site is clearly identified on this map. The dotted red line indicates the route proposed for the Jefferson Parkway. Click to enlarge.

Plutonium: The Indiana St. samples showed the presence of both plutonium-239/240 and plutonium-238 (see Figure 2). Plutonium-238 is far more radioactive than 239 because its half-life is only 87.7 years, while that of 239 is 24,110 years.

Uranium and thorium: Soil samples taken along Indiana St. as well as from more remote locations showed elevated levels of naturally occurring uranium and thorium. Though these materials are not part of the contamination from Rocky Flats, Kaltofen points out that they do represent an inhalation hazard because they contain alpha emitting particles that are in the size range of respirable particles (0.5 to 5.0 microns). This means there is more alpha radiation in the area proposed for the highway than simply that emitted by plutonium.

Hot particles: Particles that contain substantially more radioactivity than surrounding inert material and that are in the size range that can be inhaled and entrapped in air sacs of a lung are referred to as hot particles. Plutonium-bearing samples in this study contained multiple hot particles. Many of the particles catalogued in this study were in the size range that is easily inhaled and retained in the lungs. Official standards for permissible exposure are not calculated in a way that takes account of the concentrated danger posed by hot particles.

Figure 2. Location of samples collected along Indiana St. that contained either plutonium 239/240 or plutonium-238 or both. Each sample is indicated by a number assigned to it followed by its plutonium content in picocuries per kilogram (pCi/Kg). To translate into picocuries per gram (pCi/g), multiply by 1,000. Thus the 30 pCi/Kg content of sample 50S = 0.030 pCi/g, the 1,579 pCi/Kg content of sample 5S = 1.579 pCi/g. All samples are soil samples except for 44B, which shows plutonium found in tree bark at that location.

Questions about average background deposits

Plutonium is not part of natural background radiation, but due to fallout from atmospheric detonations background radiation around the world now includes some quantity of plutonium. Specifying the average background for plutonium in soil along the Front Range of the Rockies in Colorado means that deposits in excess of this amount can be attributed to Rocky Flats. The “cleanup” of the Rocky Flats site was predicated on an average background level for plutonium of 0.04 picocuries per gram of soil (pCi/g).

By contrast, according to Kaltofen’s calculation, the average background level measured by Krey and Hardy in 1970 is 0.010 pCi/g. In addition, in 1994 Scott B. Webb and colleagues at CSU in a study on “The Spatial Distribution of Plutonium in Soil Near the Rocky Flats Plant” found a median level of 0.011 pCi/g in samples collected along the Front Range more than 10 miles from Rocky Flats. Finally, an August 2002 Los Alamos National Laboratory study found between 0.010 and 0.023 pCi/g of plutonium-239 in soils and sediments of the upper Rio Grande valley of southern Colorado (LA-13974-PR). Collectively, these studies suggest that the Rocky Flats “cleanup” may have been done in a way that underestimated the amount of plutonium deposited in the environment from the Rocky Flats Plant itself. The quantities, ranging from 0.01 pCi/g to 0.04 pCi/g, are very small, but when dealing with plutonium very small amounts matter. If Krey and Hardy’s background number is more accurate, the “cleanup” may have been less protective than it should have been.

A recommendation: In response to the foregoing, the EPA and CDPHE should perform a comprehensive analysis of undisturbed soils along the Front Range in areas least likely to have been affected by Rocky Flats to arrive at a definitive calculation of average background for plutonium from global fallout in the area. This number would serve as a baseline for all future work related to plutonium in the environment on and off the Rocky Flats site.

Welcome to Golden (Flickr creative commons http://flic.kr/p/akqjsS)

“Breathes there a soul who really, truly, loves a beltway? Maybe, but you are not likely to find one here in this little city in the Rocky Mountain foothills west of Denver.  For decades, this has been the community that said no, arguing through courts and politics and whatever other means available that a multilane ring road circling Denver — the kind built around cities all across America starting in the 1950s and ’60s — would spell disaster. Most of Denver’s belt-loop would cruise through open prairie land; here it would cleave the narrow Golden Valley and shatter the community, residents and their leaders said in what became a mantra.”

Read the entire article at the NYTimes.com: City of Golden Holds Firm Against Denver Beltway.

“The City of Golden on Jan. 5, 2012, filed a lawsuit in the United States District Court for the District of Colorado against the U.S. Fish and Wildlife Service to halt the transfer of federal land for the construction of the proposed Jefferson Parkway.

“Golden’s lawsuit maintains that the Fish and Wildlife Service violated environmental and other laws when it agreed to convey a strip of land in the Rocky Flats National Wildlife Refuge to the Jefferson Parkway Public Highway Authority. Among other things, the lawsuit alleges that the Fish and Wildlife Service (1) failed to conduct adequate environmental analysis of the effects of the property conveyance and the Jefferson Parkway, (2) unlawfully rejected Golden’s separate application for the strip of land, and (3) failed to ensure that environmental effects on the Refuge were minimized.”

Read the entire article at Get the Facts Golden.

The author on a windy day in May 2011 at the southeast corner of Rocky Flats on land proposed for the Jefferson Parkway

In an article published in the Blue Line a few days ago, I reported incorrect results from citizen sampling for plutonium in soil in the area at Rocky Flats proposed for construction of the Jefferson Parkway.  The sampling effort was initiated by Rocky Flats Nuclear Guardianship, a project of the Rocky Mountain Peace and Justice Center. We wanted to determine whether highway construction would be likely to stir up a cloud of highly toxic plutonium-laden dust that would endanger workers, nearby residents and others.

In the referenced Blue Line article, I stated that the scientists we hired to do the sampling, Marco Katofen and Strongbear, a colleague from the Boston Chemical Data Corp., had found plutonium concentrations at lower levels than had previously been found in the area intended for the highway construction. I was mistaken. In fact, according to Kaltofen, their samples collected along the eastern, downwind edge of the Rocky Flats site showed plutonium concentrations that closely correspond with results from earlier sampling by others in the same area. Kaltofen and Strongbear found plutonium in 6 samples along Indiana St., the eastern edge of the Rocky Flats site. Two of these samples contained concentrations of plutonium well above what government agencies regard as average background plutonium deposits from global fallout. One came in at about 7 times background, the other at almost 40 times background.

Kaltofen is now doing additional analysis with a focus specifically on the breathable plutonium particles present within the samples he and Strongbear collected, since inhaling such particles is the most dangerous way of being exposed to plutonium. This analysis, he says, will help us see more clearly the actual danger that can result from highway construction proposed for the parkway. By early January we should have information that will help us better understand next steps.

The yellow arrows point to Section 16. The dotted red line indicates the route of the proposed Jefferson Parkway. The Candelas project is the cross-hatched area. From http://www.boulderblueline.org/2010/11/21/jefferson-parkways-layers-of-complication/ (click to enlarge)

It’s been quite a week on the Jefferson Parkway front. Consider:

Fish & Wildlife clears the way for the Jefferson Parkway

Deciding against an Environmental Impact Statement (EIS) on the Parkway/land-transfer matter, FWS (Fish and Wildlife) published their Environmental Assessment (EA) with  a “Finding of No Significant Impact” (FONSI). They’re ready to transfer a 300 foot-wide strip of land along the eastern downwind edge of Rocky Flats (Indiana St.) to the Jefferson Parkway Authority for construction of a private tollway in exchange for adding Section 16 (a plot at the southwest corner of the Rocky Flats site) to the Wildlife Refuge. The EA (500 or so pages) is on line at http://www.fws.gov/rockyflats/ea2011.html. Though the EA was signed on Dec. 2 it was not released until Dec. 15, and even on the following day was not posted on the web site of FWS. The timing and failure to do a news release on a matter of such public concern is puzzling.

Superior takes FWS to court

A lawsuit filed in federal court on Dec. 15 by the Town of Superior accuses FWS of violating the Rocky Flats National Wildlife Refuge Act as well as the National Environmental Policy Act in several respects. Here is a summary of main points of the lawsuit:

• The Sec’y. of the Interior lacks the statutory authority to transfer land.
• The EA issued by FWS failed to assess the environmental impacts of construction of the highway with respect to contamination and urban sprawl.
• The EA failed to assess the environmental impacts of adding Section 16 to the Refuge.
• The EA failed to assess the environmental impacts of the Parkway on other transportation corridors.
• The EA relies on the Northwest Corridor Study issued by the Colo. Dept. of Transportation in 2008, though this study was never submitted to the public for comment nor did it include an EIS.

For these reasons and more, the Town of Superior finds FWS’ issuance of the FONSI “arbitrary and capricious” and “not in accordance with law.” Superior seeks a full study leading to an EIS.

A deal to end Golden’s opposition to the Parkway

The Jefferson Parkway Authority and the Golden City Council are evidently close to finalizing a deal that will end Golden’s opposition to the Parkway. Though a final document has not been made available, the deal would, among other things, provide funds to “improve” Hwys. 93 and 6, the routes through Golden that would be utilized by traffic to and from the Parkway. On Thurs, Dec 15,  the Golden City Council heard comments. Opponents of the deal expect a council vote very soon, and they are not optimistic. A few months ago the Boulder City Council and Boulder County Commissioners accepted a deal to end their long-standing opposition to the Jefferson Parkway in exchange for helping pay to add Section 16 to the Rocky Flats Wildlife Refuge. Now the deal-making ball has been passed to Golden.  For more on the opposition, see http://www.gothebetterway.org/.

Results from sampling at Rocky Flats

Those of us involved in Rocky Flats Nuclear Guardianship (a project of the Rocky Mountain Peace and Justice Center) are very familiar with the map produced in 1970 by AEC scientists P. W. Krey and E. P. Hardy showing high concentrations of plutonium in soil on and off the Rocky Flats site.

Plutonium distribution in 1970

The route of the proposed Jefferson Parkway passes through the heart of the most contaminated area along the eastern border of the site. We therefore thought that construction of a highway in this area would stir up clouds of plutonium-laden dust. Accordingly, last spring we asked FWS to allow specialists in our hire, Marco Kaltofen and a colleague from the Boston Chemical Data Corp., to visit the Rocky Flats site to collect soil samples in the area being considered for the highway. The samples would be analyzed for plutonium content. FWS denied this request. So when our specialists came to Colorado in September they collected samples outside the Refuge fence along Indiana St. On Dec. 15, in the midst of dealing with the three items mentioned above, we received Kaltofen’s report on the sampling. Plutonium was present in six samples collected along Indiana St. Four of these samples showed plutonium at levels in the range of what federal and state agencies regard as average background deposits locally from global fallout — 0.04 picocuries per gram of soil (pCI/g). But two of the samples showed elevated levels, one about 7 times average background (0.270 pCI/g), another almost 40 times background (1.579 pCI/g). When I shared this information with Michael Dixon, an official of FWS, he said he was “relieved to see that the levels are not above the action threshold for the remedy that the EPA selected.” His statement brings to mind the words of Ulrich Beck in Risk Society: “Whoever limits pollution has also concurred in it. . . Acceptable values may indeed prevent the very worst from happening, but they are at the same time ‘blank checks’ to poison nature and humankind a bit.”

Locations where samples showing plutonium were collected (2011) along Indiana St.

Concluding reflection

The findings from our soil sampling are disturbing in several respects. First, the levels of plutonium are much lower than we expected, given the large concentrations Krey and Hardy had recorded in 1970. Since the plutonium used at Rocky Flats has a half-life of 24,000 years, it is dangerously radioactive for at least a quarter-million years. In human terms it poses an essentially permanent danger. The plutonium Krey and Hardy found in 1970 is still dangerous. But where is it? If it’s no longer present in the surface soil near Indiana St., it has either percolated down to deeper levels or it’s been blown away by the strong winds common at Rocky Flats. The first of these possibilities points to the need for the EIS FWS doesn’t intend to do. The second means the plutonium has been carried by the wind throughout the Denver area and beyond, some of it undoubtedly into the lungs of unsuspecting people. If they get cancer 20 or 30 years later, they’ll not know what hit them. This reality, of course, is part of the tragedy of Rocky Flats historically. Plenty of plutonium in the form of particles too small to see but not to small to do harm has been released across the metro area over the years. Yet there has never been any direct health study or medical monitoring of people who live or work in areas contaminated with plutonium released from Rocky Flats. Hence, no one really knows the actual health effects. This is a cost that has never been counted. And now the cards are stacked in a way that may prevent us from knowing the effects of building a highway along the edge of the Rocky Flats site. Carelessness trumps caution.

I learned from emeritus CSU professor Ward Whicker about 20 years ago that background deposits of plutonium from global fallout in soil along the Front Range of the Rockies in Colorado averages 0.04 pCi/g, plus or minus a factor of 2 (ranging therefore from 0.02 pCi/g to 0.08 pCi/g). I believe the determination of this number was made in the 1970s. The late Ed Martell, NCAR radiochemist, insisted that some people would become ill and die as a result of exposure to background plutonium distributed around the world. Here in the Denver area we’ve always wanted to know the effects of Rocky Flats, so we’ve tried to distinguish between background plutonium deposits and the plutonium released from Rocky Flats. If in fact plutonium released from Rocky Flats that was detected in the soil forty years ago by Krey and Hardy has blown away, what has happened to so-called background deposits? Hasn’t it blown away as well? With the decline of atmospheric testing of nuclear weapons less plutonium is available from fallout. We need a new study to determine current average levels of plutonium in soil from global fallout along the Front Range. I suspect such a study would demonstrate that we are comparing current plutonium soil sampling results with an average background  number that is inflated because it is outdated. It may be that samples that we regard as “no more than background” in fact are well above background. Who would like to join me in asking EPA and CDPHE to conduct such a study?

Last week two specialists hired by the Rocky Mountain Peace and Justice Center collected 40+ samples at Rocky Flats, primarily along the eastern edge of  the site on land proposed for the privately financed Jefferson Parkway. Earlier studies showed this area to be heavily contaminated with plutonium. Our  request to U.S. Fish & Wildlife for permission to have our sampling done on the Rocky Flats site was denied, so the samples were collected outside the fence.  We did not publicize this activity because we didn’t want to call attention to it. In five or six weeks we will know whether or not the sampling shows that highway construction in the area would stir up clouds of plutonium-laden dust that would endanger workers, nearby residents and others. We took this step because it appeared that government agencies weren’t going to do the sampling we believe should be done before land is made available for the proposed highway.

What we very much need now is financial support to help pay the cost of this work and follow-up activities, including publicity and grassroots  efforts. Details about how to support this effort are on our website.

PLAN-Boulder County is an organization of several hundred citizens established more than 50 years ago to advocate responsible environmental stewardship, good planning practices, and good government.

This letter is written in response to the [Fish and Wildlife] Service’s request for public comments as part of the scoping process for the environmental analysis of the proposed disposal of the 300 ft. transportation corridor on the east side of the Rocky Flats National Wildlife Refuge.

We understand that the Fish and Wildlife Service does not plan to include impacts on non-refuge lands in the environmental assessment being prepared pursuant to the NEPA. As you know, Federal agencies are required to include both the direct and indirect impacts of their actions in NEPA documents. By looking at only refuge impacts, the Service would be ignoring this requirement.

Moreover, we note that many of the impacts of the actions being considered were not included in the 2004 EIS, so the current NEPA process cannot rely on that document as an adequate assessment of the possible decisions.

We strongly support the expansion of the Refuge to include Section 16 on the west side of the Refuge, with provision for its acquisition, whichever path is chosen for the transportation corridor on the east side of the Refuge. Because of the wildlife corridors along Woman Creek and the valuable intact native grasslands, preservation of Section 16 is critical to the Service’s successful management of the Refuge.

We request that you reconsider the scope of your analysis to include the impacts on the lands, plant and wildlife habitat, people, and roads in areas outside of the refuge system that will be impacted by the disposal of a transportation corridor to the Jefferson Parkway Public Highway Authority or to the City of Golden. The impacts of a tollway, as proposed by the Authority or of a bikeway, as proposed by Golden, are very different in type and in intensity and therefore the non-refuge impacts from proposed uses of the transportation corridor by the Authority or by Golden must be evaluated, assessed and compared.

We therefore urge you to expand the scope and proposed schedule of your NEPA process to include a comparison of the impacts of use of the transportation corridor on the east side of the Refuge between the proposals of the Authority and of the City of Golden. In particular, the impacts that should be considered include:

• Access for bicyclists and other visitors to the Refuge, as shown in both the 2004 EIS and the 2005 Conservation Plan.
• The degree to which each of the proposals comports with regional alternative transportation plans, such as the Pedestrian and Bicycle Element in the DRCOG 2035 Metro Vision Regional Transportation Plan.
• Impacts on the communities at either end of the two proposals, particularly the City of Golden and the Town of Superior, especially of the construction of the proposed tollway. Both those communities have expressed concern about the effects of the proposed Parkway, so disposition of the transportation corridor by the Service on those communities must be considered.
• Air pollution impacts of projected traffic generated by each of the proposed alternatives.
• Regional growth and traffic congestion that can be projected as a result of each of the proposals.
• Impacts on the flora and fauna inside and outside the Refuge as a result of development on the south side of the Refuge that can be anticipated if the proposed Parkway is built. (Candelas development.)
• Relative impact of the two proposals on Prebles jumping mouse critical habitat outside the Refuge proper.
• Impacts on visitors and wildlife within the Refuge due to traffic noise and air pollution from the proposed Parkway.
• Hazards from plutonium contamination of the soils on the corridor to be transferred, and the effects that can be expected from construction of either of the alternatives. Particularly, see the map of Pre-Cleanup Plutonium Concentrations at Figure 3 of the 2005 Conservation Plan, which clearly shows the plume of contamination extending east to the transportation corridor. Note that the assumptions in both the Conservation Plan and the 1996 Final Rocky Flats Cleanup Agreement do not consider the effect of major construction disturbance of the soils. On the contrary, the assumption applies to visitors with casual exposure and no significant disturbance of the soil. The use of earthmoving equipment, particularly if the Parkway is constructed, would radically change the exposure of residents of surrounding downwind communities like Superior, Louisville, Broomfield, and Arvada, as well as communities farther east. We contend that any NEPA process considering disposition of this transportation corridor must consider these risks.

We appreciate the opportunity to comment and sincerely request that the scope of your NEPA analysis be enlarged as discussed above.

If Blue Line readers would like to offer comments to the Fish and Wildlife Service, the deadline is Friday July 29, 2011.   Please send your comments to:

Mike Dixon
Division of Refuge Planning
U.S. Fish and Wildlife Service
P.O. Box 25486, DFC
Denver, CO 80225

Bruce Hastings, Deputy Refuge Manager
Rocky Mountain Arsenal National Wildlife Refuge
6550 Gateway Road, Bldg 129
Commerce City, CO 80022

email: rockyflatsea@fws.gov

I intended to be present yesterday, Tuesday, April 26, when you made the fateful decision that Boulder County Commissioners will no longer oppose the Jefferson Parkway. But I could find no information anywhere on the County Commissioners’ web site about the time and place of this meeting. I concluded that either my memory had failed me or that the meeting had been postponed. Only this morning, looking at the Daily Camera, did I learn that this meeting in fact did take place some time yesterday.

In the preceding paragraph I use the word “fateful” to refer to your decision about the Parkway, because I think it most unfortunate that Boulder County (and soon, Boulder City) will no longer oppose the Jefferson Parkway. Will, I very well remember the conversation you and I had some weeks ago on this topic. You were quite persuasive about why Section 16 needed to be purchased in order to stop development along Hwy 93 north of Hwy 72 and that in order to accomplish this the County Commissioners were ready to give up their long-standing opposition to what is now called Jefferson Parkway. You emphasized besides that the route of the proposed Parkway is wholly outside Boulder County and that DRCLOG’s recent decision in favor of the Parkway had deprived Boulder County of any remaining shred of legal clout on the issue. I accept these arguments.

But I hate to think that those who oppose Jefferson Parkway for many reasons will no longer be able to depend on Boulder County Commissioners exercising at least moral authority (as distinct from legal authority) on an issue of import to residents of Boulder County. Construction of the Parkway along the edge of the Rocky Flats site, as you undoubtedly know, will needlessly expose unwitting people to plutonium-laden dust, that is, a highly toxic long-lived radioactive material in its most dangerous form. Some of that dust may even make its way into the lungs of Boulder County residents. You have made a fateful decision.

Jefferson Parkway Public Highway Authority officials said Monday that they are talking to a Madrid-based construction firm Isolux Corsán about financing, building and operating the 10-mile toll road in Jefferson County.The authority has touted the toll highway as one of the final links in the metro-area beltway.The Jefferson Parkway, which is estimated to cost $204 million, would run from Colorado 128 near Rocky Mountain Metropolitan Airport to Colorado 93 north of Golden.Isolux Corsán said it operates more than 1,000 miles of toll highways under concession agreements in Spain, Mexico, Brazil and India.

Read the entire article at the Denver Post: Jeffco talks to Spanish firm about toll road.

Jefferson Parkway directors, who represent Arvada, Broomfield and Jefferson County, agreed to buy a roughly 3.5-mile long and 300-foot wide sliver of the wildlife refuge — about 100 acres — for $28,000 an acre, a total of $2.8 million.

Read the entire article at the Denver Post: Jefferson Parkway authority to buy Rocky Flats parcel.